Comhairle nan Eilean Siar Equality and Diversity Impact Assessment Toolkit

ORGANISATION: Comhairle nan Eilean Siar DEPARTMENT: Social & Community Services

PERSON RESPONSIBLE: Annabel Bain SECTION: Leisure & Learning

DATE: 15th April 2009 TIMESCALE FOR IMPACT ASSESSMENT: March/April 2009

DUE DATE: NAME OF POLICY OR FUNCTION: POLICY  ASSOCIATED POLICIES OR FUNCTIONS

Has the policy or function been assessed FUNCTION X OWN ORGANISATION for relevance to the General Duty under Employability Strategy the Race Relations (Amendment) Act NEW X 2000?  PARTNER ORGANISATIONS EXISTING 

DATE STARTED: 2nd March 2009 DUE DATE: DATE COMPLETED: 15th April 2009 SUMMARY OR OUTCOME OF IMPACT ASSESSMENT: Adverse effects Not found X Found  Policy/Function amended to stop or reduce adverse effects  Consultation conducted X DATE DUE FOR REVIEW: June 2010 PERSON RESPONSIBLE FOR PUBLISHING RESULTS OF IMPACT ASSESSMENT: Director of Social & Community Services

PERSON RESPONSIBLE FOR ARRANGING REVIEW: RESULTS DUE TO BE PUBLISHED: Employability Manager June 2009

PERSON RESPONSIBLE FOR ARRANGING MONITORING: Employability Manager

SIGNED: DATE:

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1. Aim/Status (a) What is the aim/purpose of the policy/function?

To provide training and employability support for adults with additional support needs in the Western Isles. has delivered a service (OFTTI) for this client group for 16 years on behalf of the Comhairle but a report by consultants Hall Aitken in 2008 recommended separation of the current components of OFTTI with day service provision being delivered by the Social Work service and training and employability support being delivered by a new service which for the time being is being called HILLS (Hebridean Independent Living and Learning Service). This assessment refers to HILLS.

(b) Who is intended to benefit from this policy/function and in what way?

Adults with additional support needs will be given support to access training and employment opportunities. A lead agent will be contracted to deliver this service in , Uist and and the service will be tailored to meet the needs of individuals in these areas.

The new service will benefit from a defined and joined up referral framework with a common referral form allowing multi-agency input as appropriate. Lead agents will be strongly encouraged to work in partnership with other local services and providers to provide holistic support to service users. Lead agents will be expected to develop individual training plans with each service user which will identify outcomes they wish to achieve in order to progress along an employability pathway. Lead agents will also be expected to co-ordinate volunteering opportunities, work placements and supported employment opportunities for service users.

Service users will benefit from a more tailored and progression-orientated service which helps them to develop their employability skills.

(c) How have they been involved in the development of this policy/function?

Engaged in discussion with consultants (Hall Aitken). Have continued to be engaged in the development process through a combination of open meetings and 1-1 individual discussions with the Employability Manager and Adult Services Manager.

(d) How does it fit into the broader corporate aims?

Single Outcome Agreement: Local Outcome 1 The populations of the islands of the are stable, with a healthy balance of age, gender and social-economic groups.

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Local Outcome 2 The economy of the Outer Hebrides and the economies within the Outer Hebrides are thriving.

Local Outcome 3 The people of the Outer Hebrides are well educated, well trained and well skilled.

Local Outcome 4 The physical and mental health and wellbeing of the people throughout the Outer Hebrides is improved.

(e) What outcomes are intended from this policy/function?

People will achieve their full potential to learn skills and access jobs.

(f) What resource implications are linked to this policy and/or function?

There are financial implications in implementing the new service. There is a core CNES budget of £81,000 which is required to cover the costs of replacing the OFTTI service. A Fairer Fund allocation of approximately £68,000 has been made for 09/10 and there is potentially additional funding available through Mental Health and Learning Disability grant streams. This funding will have to be shared between the new employability service and the Social Work provision required to cover current OFTTI day service responsibilities. It is likely that European funding will also be sought for the employability service.

Staffing resources are also required to develop this service to the stage of implementation and to take responsibility for long term monitoring and review of the service being delivered by the lead agents.

Complete (g) to (i) for new policies/functions only. (g) What research or consultation has been completed? Hall Aitken Consultancy Report 2008 Consultation with service users, representatives and other stakeholders in Lewis & Harris, Uists & and Barra.

(h) What stage is the policy/function at? Design. Consultants proposed delivery model has been agreed in principle by the Comhairle and CNES staff are working to finalise a service specification which will be included in tender documentation.

(i) What is the target date for completion July 2009

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2. Examination of Available Data DATA (data collection could include consultants, surveys, databases, focus groups, in-depth interviews, pilot projects, complaints made, user feedback, academic publications, consultants’ reports, citizens’ juries, etc) (a) Are there any experts/relevant groups whom you can/should approach to explore their views on the issues? ENABLE, WICUSN, Western Isles Community Care Forum, Advocacy Western Isles, Mental Health support groups, Job Centre Plus, Careers Scotland, Garadh Bagh a Tuath committee, Social Work service.

(b) What do we know from the existing data, (a) Quantitative (b) Qualitative research consultations, focus groups, and analysis available in-house? Currently between 50-60 adults registered The identified client group has a wide on OFTTI across the Western Isles. range of needs in the following areas: - learning disabilities OFTTI is delivered in 3 locations: - physical disabilities , Lionacleit, . - mental health problems - alcohol and drug issues Of those registered on OFTTI, - criminal justice issues approximately 30 are accessing some form of supported employment. The activities offered by the current OFTTI service differ greatly from area to area. In A number of service users have been Stornoway activity is centred around a registered in excess of 5 years. garden base at LCC although there are therapeutic arts and crafts activities The age profile of service users differs offered as well. A supported employment from area to area – in Stornoway they service is also offered. range from 17 – 40+ while in Barra all In Uist, there is currently only a supported service users with the exception of 1 are employment service on offer. 40+. In Barra the service centres on a Staffing requirements for the current community garden in Northbay where service are as follows: service users participate in therapeutic Stornoway 2.5FTE activities. Uist 1FTE Barra 2FTE From consultation with service users, in Stornoway there is a desire to see an enhancement of training opportunities as well as more co-ordinated day service.

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There is a strong desire to continue provision of a supported employment service.

In Uist, training gaps have been identified and there is a desire for continued supported employment service.

In Barra, all service users have expressed contentment with the therapeutic service they currently receive and there is not currently an identified need to provide enhanced training opportunities. There is a need for a supported employment service but not to the same extent as in the other areas. (c) What do we know from existing data, research (a) Quantitative (b) Qualitative consultations, focus groups and analysis available externally In 2008 there were approximately 2600 The Hall Aitken report identified the economically inactive people in the following needs: Western Isles. Of those, 800 were - better awareness of opportunities interested in work and 1800 were not. - a more consolidated approach to assessment, placement and support for adults with learning disabilities - more supported employment places - a join referral system - less duplication of effort to achieve similar outcomes

Concerns exist in Lewis, Uist and Barra about the impact of the changes on day service provision. OFTTI has provided an element of day service in the past but HILLS will have a training and employability focus. Social Work will take

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responsibility for day service provision and are working to address any gaps which may arise. Individuals who have expressed concerns have been invited to discuss their own particular requirements with the Adult Services Manager.

(d) What gaps in knowledge are apparent? (a) Quantitative (b) Qualitative

The number of service users who have How and if progression is measured for shown progression in their time at OFTTI. current OFTTI clients. The number of service users who have progressed from OFTTI to positive The type of training OFTTI clients would destinations. like to access.

The number of current OFTTI service users who are likely to participate in the new service. (This information should be available once the Single Shared Assessments have been completed)

(e) If there appear to be any potential difficulties of access or compliance with the aim of the policy/service, please describe these.

N/A

3 Rapid Impact Checklist (RIC) Having carried out the RIC screening process, Have potential negative impacts been identified X please answer the following questions: for racial or other equality groups?

If yes, has a full Equality and Diversity Impact Assessment X Been recommended

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Signature of Manager: If no, are you satisfied that the conclusions of the RIC  Are accurate and comprehensive?

Date: 4. Impacts (a) What is the likely impact (whether intended or unintended, positive or negative) of the initiative on users or on the public at large?

The service should have a positive impact on users by enabling them to access enhanced training and supported employment opportunities. Service users should gain in confidence and skills through progressing at their own pace along an employability pathway.

Initially, there may be a potentially negative impact on users as they become familiar with a new service operated by potentially different personnel from those they have been used to. Those managing the new service will be expected to work closely with service users and their representatives to minimise any negative impacts through the transition period.

Staff currently employed through the OFTTI service may be negatively impacted if they are not redeployed, the Comhairle is working with LCC to minimise any negative impact on this group.

(b) Is there likely to be a differential impact on any group? If yes, please state if this impact may be adverse and give further details (eg which specific groups are affected, in what way, and why you believe this to be the case?

(i) Grounds of race, ethnicity, colour, nationality or national origins e.g. People of different  Yes X No Adverse?  Please give further details ethnic backgrounds including minorities: Gypsey Travellers and Refugees / Asylum Seekers

(ii) Grounds of sex or marital status: Men and Women  Yes X No Adverse?  Please give further details

(iii) Grounds of gender: Transgender or transsexual people  Yes X No Adverse?  Please give further details

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(iv) Grounds of religion or belief: Religious / Faith or other groups with a  Yes X No Adverse?  Please give further details recognised belief system

(V) Grounds of physical or sensory impairment or mental disability: X Yes  No Adverse?  Please give further details Disabled people The impact on this group is intended to be positive by increasing their opportunities to access training and supported employment. (vi) Grounds of age: Older people; Children and Young people  Yes X No Adverse?  Please give further details

(vii) Grounds of sexual orientation: Lesbian, gay, bisexual  Yes X No Adverse?  Please give further details

(viii) Grounds of offending past  Yes X No Adverse?  Please give further details

(ix) Grounds of mental health X Yes  No Adverse?  Please give further details

The impact on this group is intended to be positive by increasing their opportunities to access training and supported employment. (x) Other Grounds (e.g. proverty, people in the criminal justice  Yes X No Adverse?  Please give further details system, married / unmarried / civil partnerships, people with language or social origin issues, employees) (c) Is the policy directly discriminatory? (d) (i) Is the policy indirectly (e) Is the policy intended to increase equality of discriminatory? opportunity by permitting positive action or action to  Yes X No redress disadvantage?  Yes X No (under any discrimination legislation eg sex X Yes  No Discrimination Act, Race Relations Act, (ii) If you said yes, is this objectively Disability Discrimination Act, Religion or justifiable or proportionate in Please provide details:

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Belief Regulations, Sexual Orientation meeting a legitimate aim? Regulations or relevant policy) The service is intended to give people with learning  Yes  No disabilities, physical disabilities and mental health problems the opportunity to progress along an employability pathway through enhanced access to training and supported employment. It is anticipated this service will increase this client group’s opportunities to move towards independent living.

If you answered yes to Q3 (c) and no to Q3 (e), this is unlawful discrimination.

If you answered yes to Q3 (d) (i) and no to Q3 (d) (ii) and no to Q 3 (e), this is unlawful discrimination.

If the policy is unlawfully discriminatory, you must decide how to ensure the organisation acts lawfully.

(f) If the policy is not directly or indirectly discrimatory, does it still have an adverse impact?

 Yes X No Please provide details:

5. Modifications In your consideration of the next questions, you should think about the following: . How does each option further or hinder equality of opportunity? . How does each option challenge or reinforce sterotypes which influence equality of opportunity? . What re the consequences for the group(s) and the public authority of not adopting an option more favourable to equality of opportunity? . What are the social/economic costs and benefits or implementing each option? (Social status, Employment (paid or unpaid); Stress; Income; Living conditions; Working conditions; Pollution or climate change; Accidental injuries or public safety; Transmission of infectious disease) . Will the proposal affect access to and experience of services? (Health care; Social Services; education; Transport; Housing) . Will the benefits of implementing the change outweigh the costs? (proportionality) (a) If you answered yes to Q3 (f) and the policy would have an adverse impact on any group, how could you modify the initiative to reduce or elimate any identified negative impacts, or to create or accentuate positive parts of the development?

While on balance there is no adverse impact, there may initially be difficulties relating to transition arrangements, transport and personnel which will require to be overcome. Existing staff, future staff, CNES personnel should work together with service users and

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their representatives at the earliest opportunity to minimise these difficulties.

(b) If you make these modifications, would there be impacts on other groups in society or on the ability of the initiative to achieve its purpose?

N/A

6. Further Research (a) Given the analysis so far, what additional research or consultation is desirable to investigate the impacts of the proposal on diverse groups?

The Single Shared Assessment process will provide information on the needs and aspirations of individuals which will help to inform the provision developed by the new service.

Further scoping of how Social Work will meet the needs of those current OFTTI clients for whom a training and employability service is not an appropriate option.

(i) new primary data? (ii) secondary analysis of existing data?

X Yes  No  Yes X No

Describe: Describe:

Single Shared Assessments being carried out by the Community Care team.

(b) What steps do you need to take to ensure that the right people are involved in this research?

Ongoing communication required between key stakeholders and service users and their representatives.

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7. Consultation Under the Race Relations (Amendment) Act 2000 you are required to consult on the impact of new policies, functions and service changes (a) What are the aims of consultation? The consultation undertaken by Hall Aitken in 2008 was intended to identify the gaps in the current OFTTI provision and identify a model which would better meet the needs of the client group.

Further engagement has been undertaken by the Employability Manager and the Adult Services Manager to identify how the lead agent model recommended by Hall Aitken and approved by the Comhairle can be developed and implemented to the best effect for current and potential service users and to minimise any negative impact on these service users.

(b) What is the planned timescale? (c) Who is responsible for managing the consultation? Consultation by the Employability Manager and the Adult The Employability Manager and the Adult Services Manager jointly Services Manager took place in March – April 2009 managed the consultation.

(d) Whom do you need to consult? (e.g. What groups must be included? Consider beneficiaries, stakeholders and others who may be affected) The initial consultation undertaken by Hall Aitken involved service users, carers, potential deliverers, OFTTI staff, representatives of the ENABLE group, voluntary organisations and local councillors.

The second phase of consultation has involved service users, carers, OFTTI staff and other interested stakeholders.

(e) What methods of consultation are proposed? (f) What methods are being considered to ensure full information and Separate meetings for interest groups (service users, participation? carers/representatives, staff, interested stakeholders) held in  Accessible formats? Lewis & Harris, Uists & Benbecula and Barra.  Community Languages?  Oral information? Drop-in sessions were also arranged so service users and/or X Taking account of different needs? carers could discuss their individual needs on a 1-1 basis.  Taking account of different customs, festivals, etc? X Accessible venues e.g acoustics, transport, wheelchair access, loop/signing/translation facilities? X Use of advocates  Training or other support for potential participants?  Other – please give details

(g) What other consultation exercises are planned? (can they be “joined up”?)

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The service user engagement ties in with the Single Shared Assessment process currently being undertaken by Social Work to assess the needs of current OFTTI service users.

(h) How will consultation outcomes be fed back into the process? Outcomes will be taken account of in the procurement specification for the new HILLS service.

(i) Following consultation, what is the RECOMMENDATION?  Reject the policy/function X Introduce the policy/function  Amend the policy/function  Other (an impact assessment should be made of any amended policy) 8. Decision-making and Reports to Line Management/Members (repeat this section for each stage of the decision-making process.) (a) Who will make the decision? (Essential to consider also in partnership developments). Decision will be made by Comhairle members on a recommendation by the Director of Social and Community Services.

(b) Following consultation, what is the DECISION?  Reject the policy/function X Introduce the policy/function  Amend the policy/function  Other (an impact assessment should be made of any amended policy)

9. Monitoring and Review (a) How will the implementation of the policy/function be monitored? A monitoring and evaluation system will be established for the HILLS programme. Each lead agent will be required to monitor and report on achievement of set outcomes at regular intervals. It will be important for lead agents to be able to demonstrate progression by their service users.

(b) How will results of monitoring be used to develop future policy/function and practice? Results of monitoring will be used to assess effectiveness of this particular model of employability support and if the results show success, the model may be rolled out to incorporate wider aspects of the employability agenda in the long term.

Results of monitoring will also be used in reviewing the service when the initial contract is due for renewal.

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(c) When is the policy/function due to be reviewed?

Date: It will be reviewed after one year (June 2010) then at the end of the service contract.

10. Public availability of Report/Results What are the arrangements for publishing?

(i) Results of the impact assessment - will be available on the CNES website and hard copy on request.

(ii) Results of the consultations – available on request

(iii) Employment Monitoring outcomes – available on request

(iv) Other Monitoring outcomes (eg service users, non users, stakeholder views) – available on request

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