Impact assessment

People and equality impact assessment for HMRC's locations programme (2023)

Updated 22 March 2023

Introduction

HM Revenue and Customs (HMRC) is committed to eliminating unlawful discrimination, advancing equal opportunities, promoting good relations between people and improving or promoting equality. To help with this and meet our legal duty as a public body, HMRC uses equality analysis to consider the effect of policies and practices on different groups protected from discrimination by equality legislation. We also use People Impact Assessments to help think through the implications of change on our people.

The Locations Programme has merged equality analysis and people impact processes and produced a consolidated People and Equality Impact Assessment (PEIA) where we identify potential risks or adverse impacts through equality analysis and consider what we can do to reduce or mitigate those impacts. This PEIA builds on our earlier versions. It summarises the impacts of our Locations Strategy and the actions we’ve taken to minimise them.

Background

Our Locations Strategy is key to enabling HMRC’s wider transformation. It has successfully delivered safe, modern, and inclusive workspaces which improve collaboration, promote smarter working and a culture where everyone feels valued. These regional centres are phase 1 government hubs and provide greater opportunities for career development in every region and nation of the United Kingdom.

Since the last PEIA in December 2021, we successfully completed the first stage of phase 1 government hubs, opening 3 more regional centres in Glasgow, Nottingham and Manchester and closing a further 10 offices.

The second, smaller stage includes moving from offices in Longbenton and Washington, to a new city centre location at Pilgrims Quarter, in Newcastle in 2027; establishing a long-term presence in Portsmouth (our 14th regional centre) and East Kilbride, which will become the second phase of our Glasgow Regional Centre.

HMRC also expects to close its offices in Peterlee later in March 2023, Reading (2024), Preston (2025), Bradford (2027) and Salford (2028). HMRC will continue to monitor the impacts associated with the second phase of activity at regional level.

We always recognised our locations strategy would mean difficult decisions for some groups. We’re committed to helping as many people as possible to move and have worked closely with key stakeholders including trade unions and colleague networks to identify, monitor and take action to reduce the impacts. To support our people, we introduced a wide range of policies and processes, including workplace adjustments, financial support for those faced with increased travel and carers costs resulting from a longer journey to work.

In addition, analysis undertaken in 2019 to 2020 indicated that longer, or more complex journeys were key factors behind people leaving HMRC. Those who wanted to stay with us said more flexible working, particularly the ability to work from home more often, could have helped them stay.

The changes introduced as part of Pay and Contract Reform mean that colleagues now work a mix of home and office working, with most working from home at least 2 days a week. Significantly, we now offer employees who said they would otherwise be unable to move, increased flexible working options, including the opportunity to work from home permanently, to enable them to stay with us. In locations that have closed since Pay and Contract Reform was introduced, around 900 people have taken up these flexibilities and stayed with us.

Main findings 2022 to 2023

In 2015, when we started our Locations Programme, we estimated that 90% of people at that time would either be able to move to a regional centre or see out their career with HMRC. We remain on track to meet this estimate.

Since the last PEIA, we reviewed and improved our method for determining which colleagues have left HMRC as result of the Locations Programme. This makes it difficult to make comparisons between the exit data provided in the last PEIA and this one. The figures provided are based on the current method of determining which exits are related to the Locations Programme.

Between the start of the Locations Programme and 31 October 2022, around 44,500 people had a formal one-to-one, opted into moving or had the opportunity to have a conversation with their manager to discuss their circumstances, the available options and any support they might need. In the same period around 5,200 people left HMRC, with just over 600 people leaving since 1 October 2021, because of a location move.

As we expected in 2021, despite the additional financial support and flexibility introduced, the moves to regional centres continue to have a greater impact on some groups. We’ve analysed the impact on single characteristics and combinations.

The largest difference in impact by equality characteristic continues to be age – 46% of people in closing offices were aged 50 or over compared to 73% of those who left HMRC. This impact is unchanged from the 2021 PEIA. The biggest combined impact was sex, working pattern and age – 13% of people in closing offices were women who worked part time and were aged 50 or over, compared to 27% of people who left HMRC.

These analyses rely on colleagues voluntarily recording their diversity characteristics in our HR system. Where declaration is lower, the reliability of our equality analysis is lower. As of 31 January 2023, 73% of people had recorded whether they were disabled, and only 45% declared whether they had caring responsibilities for children or for disabled or elderly adults. From these incomplete data sets, analysis of our exit data using the diversity data we hold suggests the impacts on disabled people and carers remain:

• 16% of people in closing offices were disabled, compared to 18% of those who left - the impacts on this group have decreased slightly since the 2021 PEIA which found that 15% of people in closing offices were disabled, compared to 19% of those who left

• 24% of people in closing offices had caring responsibilities for an elderly or disabled person, compared to 46% of those who left - the impacts on this group have increased slightly since the 2021 PEIA which found that 24% of people in closing offices had caring responsibilities for an elderly or disabled person, compared to 45% of those who left

Conclusion

We recognise that while the Locations Programme has delivered significant benefits, location changes have meant difficult decisions for some colleagues. We’re confident that the wide range of policies and processes we put in place continue to be a reasonable, proportionate and effective way to support people to continue their careers with HMRC.

This support includes additional financial support for increased travel and caring costs. It offers a mix of home and office working as standard and significantly increased flexibility, including the opportunity of permanent home working for colleagues who can’t move. Together these are helping many more people stay with us.

To improve our understanding of the impacts of our policies on different groups of colleagues, we would need a complete picture of our workforce. While some information is available from our HR records, other key information, including details of ethnicity, disability and caring responsibility, requires individuals to make a declaration – the higher the declaration rate the more accurate our data is. While the declaration rates for all groups have increased since the last PEIA, they remain lower than our target of 85%, with rates for carers significantly lower. We’ll continue to work with partners across the department, including Trade Unions and colleague diversity networks, to encourage more people to make declarations.

We’ll continue to listen to and act on feedback on the impacts of HMRC’s regional phase 2 activity.

Annex - HMRC diversity data

HMRC’s diversity data is an aggregated and anonymised version of the information we hold about the make-up of our workforce. Where the number of people in a group is small, we round and suppress data to retain confidentiality and ensure no individuals are identifiable.

The only information we have a complete picture of is the age, sex (male or female) and working pattern of our workforce – all other categories require colleagues to make a voluntary diversity declaration in our online HR system. Declaration rates for all categories are currently below our 85% target and for some categories they are significantly lower. The higher the declaration rate the more accurate a picture we have about our workforce and the better we’re able to monitor the impact of the Locations Programme and understand what’s happening in practice.

We use a question on gender reassignment and a question on self-declared gender to understand the number of trans and non-binary colleagues in HMRC. However, given the very small numbers in these categories we have not been able to conduct any analysis on the impacts of the locations programme on these groups.

How this data compares with other data sources

This diversity data provides details of the make-up of our workforce at 4 specific points of time:

1. 31 March 2017
2. 31 March 2019
3. 31 March 2021
4. 31 March 2022

Here we’ve combined the data from staff in post data and reflected changes since 2017 to both the overall colleague numbers and the diversity make-up of our workforce. These changes are due to a range of factors including recruiting new colleagues, others resigning or retiring each year, and people leaving because of location moves.

While there is no direct link between the exit data used to identify the impacts on groups in the PEIA and HMRC’s diversity data, there is some correlation between them. For instance, the diversity data indicates a reduction in the proportion of women, part-time colleagues and particularly women and colleagues aged over 50, since 2017. This corresponds with the exit data which shows a higher proportion of people with these characteristics leaving because of location moves.

The number of colleagues with caring responsibilities was not available in 2017. Despite the declaration rate slightly increasing between 2019 and 2022, it remains low overall, with just under 60% of colleagues not recording their caring status.

The data available indicates an increase in the proportion of colleagues with caring responsibilities for either a school-aged child or an elderly or disabled person. The exit data indicates an impact on colleagues who had caring responsibilities for an elderly or disabled person but there was no impact on those caring for a school-aged child.

All figures have been rounded to the nearest 5.

Diversity data tables

Workforce representation by sex (male or female)

Period	Headcount	Female	Male
As at 31 March 2017	68,095	37,975 (56%)	30,120 (44%)
As at 31 March 2019	63,950	34,740 (54%)	29,357 (46%)
As at 31 March 2021	62,770	33,175 (53%)	29,595 (47%)
As at 31 March 2022	67,509	35,359 (52%)	32,150 (48%)

Workforce representation by working pattern - full-time

Period	Female	Male	All colleagues
As at 31 March 2017	57%	87%	70%
As at 31 March 2019	57%	86%	70%
As at 31 March 2021	61%	87%	73%
As at 31 March 2022	66%	89%	77%

Workforce representation by working pattern - part-time

Period	Female	Male	All colleagues
As at 31 March 2017	43%	13%	30%
As at 31 March 2019	43%	14%	30%
As at 31 March 2021	39%	13%	27%
As at 31 March 2022	34%	11%	23%

Workforce representation by age

Period	16-19	20-24	25-29	30-34	35-39	40-44	45-49	50-54	55-59	60-64	65+
As at 31 March 2017	0%	6%	9%	9%	10%	10%	14%	18%	15%	7%	2%
As at 31 March 2019	0%	4%	10%	9%	11%	10%	13%	17%	16%	8%	2%
As at 31 March 2021	0%	5%	11%	10%	11%	11%	11%	15%	15%	8%	2%
As at 31 March 2022	0%	5%	12%	12%	11%	12%	10%	13%	14%	8%	2%

Workforce representation and diversity declaration rate disability

Period	Disabled	Non-disabled	Chose not to declare	Not known
As at 31 March 2017	9%	53%	5%	34%
As at 31 March 2019	9%	56%	5%	30%
As at 31 March 2021	9%	55%	5%	31%
As at 31 March 2022	9%	58%	5%	28%

Workforce representation and diversity declaration rate ethnicity

Period	Ethnic minority	White	Chose not to declare	Not known
As at 31 March 2017	8%	64%	5%	23%
As at 31 March 2019	10%	64%	5%	21%
As at 31 March 2021	11%	62%	4%	23%
As at 31 March 2022	13%	62%	4%	22%

Workforce representation and diversity declaration rate sexual orientation

Period	Heterosexual	LGBT+	Chose not to declare	Not known
As at 31 March 2017	50%	2%	8%	40%
As at 31 March 2019	55%	3%	8%	34%
As at 31 March 2021	55%	3%	7%	35%
As at 31 March 2022	58%	4%	7%	31%

Workforce representation and diversity declaration rate by caring responsibility for school-aged children

Period	Yes	No	Not assigned (no declaration)
As at 31 March 2017	N/A	N/A	N/A
As at 31 March 2019	4%	11%	85%
As at 31 March 2021	9%	22%	69%
As at 31 March 2022	11%	30%	59%

Workforce representation and diversity declaration rate by caring responsibility for disabled/elderly person

Period	Yes	No	Not assigned (no declaration)
As at 31 March 2017	N/A	N/A	N/A
As at 31 March 2019	3%	12%	85%
As at 31 March 2021	7%	24%	69%
As at 31 March 2022	9%	32%	59%

NOTE: all % figures are rounded and may not add up to 100%