Remote (Including Home) Working Policy

Document name: Remote Working (including home working) Policy

Document type: Human Resources Policy

Staff group to whom it applies: All staff within the Trust

Distribution: The whole of the Trust

How to access: Intranet and internet / ward folder

Issue date: October 2006

Next review: July 2010 Extended to January 2012 (agreed by EMT 10.02.11) Approved by: Executive Management Team

Developed by: Remote Working Group

Director lead: Director of Human Resources and Workforce Development

Contact for advice: Human Resources Manager or other relevant specialist advisor. REMOTE (INCLUDING HOME) WORKING POLICY

1 Introduction

1.1 To ensure that the Trust’s Vision, Values and Goals become a reality the Trust must continue to attract, develop and retain high quality staff. The Trust is committed to ensuring staff are able to achieve a healthy work/life balance. The Trust has developed ‘Guidance on Flexible Working Time’ which provides a range of flexible working options and this should be read in conjunction with this document.

One example of flexible working is remote (including home) working. The purpose of this document is to establish the Trust’s human resources policy, and associated procedures, in relation to remote access working.

Line Managers will consider requests for flexible working in consultation with individual members of staff, and may wish to confirm such arrangements with their senior manager and a Human Resources manager.

1.2 Remote working can be of benefit to the Trust and to staff in the following ways:

For the Trust remote access working can:

 Support the efficient and continual functioning of the Trust.

 Make available limited expertise or resources.

 Enable staff to effectively meet their contractual obligations.

 Aid the retention of skilled and experienced staff whose personal circumstances change and who may otherwise have to resign from the Trust.

 Enable learning and development activity to be undertaken remotely, including e-learning.

 Enable the Trust to respond to an individual’s need for flexibility in working arrangements, for example to support staff with responsibilities as carers.

 Enable disabled employees to retain their existing employment and support the recruitment of disabled applicants.

 Resolve short or longer term office accommodation issues.

1 1.3 For staff remote access working can:

 Enable them to work more effectively on a particular piece of work, where concentration is important, by avoiding the interruptions that are part of the office environment.

 Provide a solution to a temporary problem where travel to the office is not possible.

 For peripatetic staff, reduce the time spent travelling to a specific base in order to access clinical or administrative systems.

However while this form of working can provide benefits to the Trust and to staff, it also brings with it risks and other associated costs (see below).

2 Purpose and Scope of this Policy

2.1 This policy covers the provision of facilities by the Trust to enable staff, working for or on its behalf, to have secure and reliable access to any of the Trust’s information systems which they have been authorized to use. This remote access could be from locations other than their usual office base and/or from their own home.

This form of working can cover a spectrum from ad hoc, occasional remote working to forming a substantial percentage of a person’s normal working life. By and large this policy covers the issues related to staff from home on an ad hoc or occasional basis. It is expected that due to the nature of the Trust’s business that staff will be required to be either present on Trust premises, travelling or working in the community visiting service users/ colleagues for the majority of the working time. This policy does not cover the issues related to true home working or ‘teleworking’ where an individual is contracted to work 100% from their own home. If a proposal is made that an employee is to spend the majority or all of their working time based at home advice must be sought from an HR Manager.

It is recognised that within integrated services Trust staff will be working alongside staff employed by the Local Authority. Local Authority staff will need to refer to their own organisational policies regarding remote working.

3 Principles

Managers and individual members of staff should be mindful of the following principles when considering a request for a non-standard or a

2 more flexible working arrangement (see Guidance on Flexible Working for more information).

 The Trust would wish to be as accommodating as practicable in responding to requests. However, some options may not be operationally practical for certain jobs.

 Operational feasibility and quality standards, including health and safety, confidentiality and legislative requirements, must not be compromised.

 The appropriate manager should consult colleagues and staff who may be affected by the requested change, before a decision is confirmed. A flexible work arrangement for one should not be to the detriment, or inconvenience, of other colleagues.

 Managers may choose to consider a particular option to improve and enhance service delivery.

 Flexible working arrangements must be reciprocal and be beneficial to both the individual and the service/department.

 Contractual changes to terms and conditions of service can only be agreed following careful consideration of the implications and proper understanding of the individual’s circumstances.

The application of flexible working should not result in the Trust incurring additional costs, other than specific IT equipment costs.

4. Impact on Employment

The Trust’s Guidance on Flexible Working Time (separate document) details the legal implications that managers and staff will need to consider which may relate to certain flexible working options including remote working.

Legal issues It is essential that managers consult with a Human Resources Manager when an employee requests a significant change in the method of working, e.g. home working. Advice can then be given on the impact of the working pattern requested according to current legislation. Employment legislation and case law places obligations on the Trust when considering requests for flexible working and managers will need to be aware of these. The following legislation will need to be considered as part of approval process for remote working:

3 4.1 Flexible working can be advantageous to those with caring responsibilities and those with medical problems or disabilities, particularly when considering reasonable work adjustments, in accordance with the requirements of the Disability Discrimination Act (1995). (See Trust’s Managing Attendance Guidance)

4.2 The Working Time Regulations which places restrictions on working excessive hours came into force on 1 October 1998 would need to be considered as part of a request for remote working. It is the policy of the Trust to discourage long working hours wherever possible, however staff may agree in writing to opt-out of the working time restrictions. Staff are also required to get permission from their line manager before they engage in any work outside of the Trust. If the combined hours each week exceed 48 hours then a written opt out agreement, signed by both parties is required (see Appendix 1 – 1c of the Guidance on Flexible Working Time document). However, if your manager believes this to be a health and safety risk permission may be withheld. Please refer to the Guidance on Flexible Working Time document for the main elements of the Working Time Regulations:

4.3 The Flexible Working Regulations apply from April 2003 (enacted through the Employment Rights Act 2002). The Regulations give employees a statutory right to apply for flexible working if they have parental responsibility (parents, guardians, adopters) for children under 6 or a disabled child under 18. This relates to the hours worked, times that they are required to work, and working from home. This entitlement also extends to wife, husband or partner of the ‘main carer’ providing they have responsibility for the upbringing of the child/children. The Trust has a duty therefore to consider these requests seriously.

In accordance with the Act, the Trust is however, entitled to refuse a request if one or more the following reasons apply:

 Burden of Additional Costs  Detrimental impact on quality  Detrimental affect on ability to meet  Insufficiency of work during the Customer demands periods the employee proposes to work  Inability to reorganise work among  Detrimental impact on performance Existing Staff  Inability to recruit additional staff  Planned structural changes

However the options detailed in this Guidance are available for anyone to apply for.

4 4.4.1 Data Protection Act

The Trust as data controller for staff, member and service user person identifiable information, must comply with eight, legally enforceable, principles of good practice for all processing.

5 Duties within the Organisation

5.1 Managers’ responsibilities are:

 To be responsible for the approval or otherwise of all requests for remote working in line with the guidance within this policy.

 To review any existing remote working arrangements for staff within their area of responsibility in line with the guidance contained within this policy. To ensure that all staff undertaking remote working within their area of responsibility receive a copy of this document and sign Appendix 1.

5.2 Individual Trust staff’s responsibilities are:

 To ensure they are familiar with the content of this document if they are working remotely.

 To comply with all conditions contained within this document, for example regarding confidentiality, data protection, health and safety, working hours etc.

 To speak to their manager with any requests for advice or clarification as required.

 To report to the Trust immediately should they be loss, theft or damage to Trust IT equipment or the loss of confidential information.

5.3 Information Governance Trust Action Group’s responsibilities:

 To review the arrangements for remote working on a regular basis.

 To monitor the use of Trust equipment and compliance with this Policy

5 6 Development of Procedural Document

6.1 Prioritisation of work

This document has been developed so that the Trust and it’s employees may benefit from Remote Working whilst ensuring the subsequent risks are managed appropriately.

6.2 Consultation and Communication with Stakeholders

This policy and subsequent programme was developed in consultation with Human Resources, Portfolio Managers Performance and Information and Staff side representatives.

6.3 Approval of Policy

 The director lead for this policy is the Director of HR and Workforce Development.

 The Executive Management Team is responsible for the final approval of this policy.

6.4 Identification of Stakeholders

Stakeholder Level of involvement Executive Management Consultation, final approval Team

Extended Executive Allocated lead, development, Management Team consultation, receipt, circulation Information Governance Development, consultation, Trust Action Group dissemination, implementation, monitoring

6.5 Equality Impact Assessment

See Appendix 2

7. Procedures for approving Remote Working Arrangements

7.1 The Trust’s Guidance on Flexible Working Time details the procedure to be followed if a member of staff requests a flexible working arrangement. These procedures will ensure the Trust complies with legislation contained within the Flexible Working Regulations 2003.

6 While remote access working can be seen to support more flexible working practices it should be seen as an exception and not the rule. Remote working is not a guaranteed right and authorisation and support for remote working remains at the discretion of the Trust.

Staff wishing to be authorized and supported for remote access working should:

 Be supported by their line manager.

 Ensure that they meet one or more of the benefits identified above.

 Have access to suitable IT equipment and/or an authorized budget to support additional costs.

 Meet applicable Health & Safety requirements.

 Meet applicable Data Protection, Security and confidentiality of materials requirements.

 Meet one or more of the characteristics identified in the paragraph below.

Experience gained from other organisations would appear to support the view that those people most suited to remote access working have the already proven ability to:

 Work without close supervision or other management requirements.

 Meet deadlines and manage workloads.

 Demonstrate self motivation and discipline.

 Be self reliant and able to cope with reduced social contact with work colleagues.

 Manage the proximity of home and work life.

Authorisation will be subject to completion of the applicable forms and agreement by the General Manager/ Director.

Please refer to the Guidance on Flexible Working Time document for further information on dealing with formal requests for flexible working including Remote Working. There may also be circumstances where the Trust enables a discreet group of staff to

7 work remotely. The senior manager must ensure that the following issues are properly considered and the checklist at Appendix A is completed.

8. Managing The Risks Associated With Remote Working (Including KEY ORGANISATIONAL ISSUES RELATED TO REMOTE WORKING )

While the ability of the Trust to have assured, secure remote access facilities can provide the opportunity for the increased development of flexible working practices it also gives rise to a series of other key organisational issues including:

1. Eligibility criteria and authorisation 2. Health and Safety (including risk assessment of the home environment). 3. Data Protection, Security and confidentiality of materials. 4. Flexible working arrangements and performance management 5. Allocation of equipment and financial support. 6. Insurance arrangements 7. Council Tax/Business Rates

The remainder of this document clarifies the Trust’s approach to these issues. The risks associated with remote working will be mitigated by the procedures outlined in this section.

8.1 Eligibility Criteria and Authorisation

Remote working can provide specific benefits to both individual staff members and the Trust. However, there are certain organisational issues which must be considered before a request for remote working can be approved. In addition, there can be significant financial costs that arise in providing the IT equipment to enable remote working. Therefore, the General Manager or Director must approve all requests for remote working.

Health and Safety (including risk assessment of the home environment)

The Health and Safety at Work etc Act 1974 (HSWA) places duties on employers, self-employed people and employees which impact on the content of this policy. Under the Act employers have a duty to protect the health, safety and welfare of their employees, this clearly covers those working remotely including at home. While this policy does not cover true home working, i.e. where an individual works 100% from their own home, it is clearly recognised that remote access working could take place from an individual’s home.

8 Staff who work at home have individual responsibilities under Health and Safety regulations. They are required to take reasonable care of their own health and safety and to cooperate with the Trust as necessary to comply with statutory obligations, for example, by allowing one of the Trust’s Managers to examine any equipment supplied by the Trust or to visit the home.

Under the Management of Health and Safety at Work Regulations 1999, employers are required to do a risk assessment of the work activities carried out by homeworkers. The Trust’s Risk Assessment Policy should be read in conjunction with this document.

Completing a risk assessment involves identifying the hazards relating to the homeworkers’ work activities and deciding whether enough steps have been taken to prevent harm to them or anyone else who may be affected by their work. A risk is the chance, great or small, that someone will be harmed by a hazard. A hazard is anything that may cause harm.

The Health and Safety Executive has produced guidance on Homeworking for employers and employees. The guidance includes advice around the following common hazards in homeworking:

 Handling loads

 Using work equipment including electrical appliances at home

Working with VDU

 Specific duties to assess risks specific to new and expectant mothers

 First Aid

The HSAW Act also provides for safety representatives appointed by a recognised trade union to represent employees including home workers. Employees have a duty to report immediately all faults which may be a hazard to their own or others health and safety.

Trust managers should seek advice regarding any specific concerns around health and safety issues and complete Risk Assessments to cover the activities of those working remotely and at home.

For all remote working arrangements a Display Screen Assessment should be completed and shared with the user’s manager.

9 The Trust will only authorize remote access working where Health and Safety requirements have been appropriately addressed.

8.3 Data Protection, Security and Confidentiality of Materials

8.3.1 Confidentiality Issues

The employee will have to take responsibility for the confidentiality of any records held at home either on paper or electronic media and for their transportation to and from work. Any spare documents for instance amended documents must be disposed of according to Trust policies. The employee must satisfy their line manager that the precautions taken are adequate to protect the Trusts responsibilities with regard to the Data Protection Act. As such home working is not suited to staff whose main task is to update or process patient or staff records.

Not all information used contains personally identifiable details but some information will still be confidential to the Trust. Staff should ensure they hold only the minimum level of confidential information remotely. The risks associated with a particular employee working from home will depend on the nature of the work, the type of records used and the access required and the employees home circumstances.

The manager will need to satisfy themselves that the risk associated with remote including home working have been adequately dealt and this policy and procedure should be read in conjunction with the Trust’s Confidentiality Policy and Records Management Policy.

The checklist at Appendix 1 must be used to ensure that all risks have been properly considered.

8.3.2 Security issues for all electronic devises such as Computers, mobiles, PDAs, memory sticks etc

Personal confidential information held on electronic devices must be held securely. Managers should ensure their staff:

 Know their responsibilities under the Data Protection Act, Trust’s IM & T Security policy.

 Never leave a computer with personal confidential information on screen.

 Never leave your computer ‘logged on’ when unattended.

10  Ensure that rooms containing computers and other equipment, are secure when unattended, with windows closed and locked and blinds or curtains closed.

 Levels of Home Security should be at the same level as at work.

 Do not hold person identifiable information on electronic devices.

 Connect to the Trust network on a regular basis.

8.3.3 E-mail, Intranet and Intranet Facilities

Use of these facilities is encouraged, subject to certain conditions as described in the Trust’s Network security, Information Security, Intranet and E-mail Policies. In particular, facilities may not be used for the viewing, receipt or distribution of material that might be considered offensive, that breaches copyright or other legislation or that might bring the Trust in to disrepute for any reason. Trust facilities may not be used for business purposes, other than legitimate Trust business. Access to the Internet, other than for legitimate Trust business, is prohibited except during off-duty hours (i.e. before or after your shift, or during official breaks).

Staff should not use their personal email address except in exceptional circumstances. Staff should not connect Trust IT equipment directly to the internet without the use of a VPN token to ensure that data held on the IT equipment as well as the Trust computer network is not compromised.

Failure to adhere to Trust policies may lead to withdrawal of the facility and/or disciplinary action being taken. The Trust will only authorise remote access working where Data Protection, Security and confidentiality of materials requirements have been appropriately addressed.

8.4 Remote Access Working and Performance Management Arrangements

Trust managers and staff must ensure that appropriate performance management arrangements are maintained when remote working is approved. As detailed further in the Guidance on Flexible Working Time any type of flexible working needs to be regularly reviewed so that both service and individual needs are being met.

The hours to be worked at home should be agreed to allow specific, measurable targets to be set and regular feedback on performance. The manager and staff member are then able to agree communication arrangements so that each party is contactable during agreed times of the day. Normal rules regarding the management of attendance will apply for

11 any remote working arrangement. It is particularly important that members of staff who become ill during a period where they are working remotely inform their line manager in the same way as if they were at work.

Access to IT facilities when working from home should be considered in conjunction with the document ‘Allocation of Remote Working Facilities’ located on the intranet.

8.5. Allocation of Equipment and Other Financial Support

As detailed above Trust managers and staff must ensure that adequate facilities are provided where a remote working arrangement has been approved. As there will be limited funding available to ensure staff have adequate access to IT networks any funding needs to be confirmed before an application is approved.

Costs associated with remote working will be limited to those incurred to enable the employee to access IT facilities and the use of stationary that would have been used had the employee been at work. It is not expected that additional costs will be paid by the Trust, for example around home lighting/heating, electricity etc.

All members of staff are personally responsible for the safe use of equipment provided by the Trust, any loss or damage to equipment must be reported immediately. All equipment must be returned to the Trust prior to an employee leaving their employment.

8.6 Insurance Arrangements

All members of staff must contact their mortgage lenders, insurers or landlords to confirm there are no restrictions on home working. Failure to inform domestic insurers may result in home insurance cover rendered invalid.

Trust managers must also confirm that any IT Trust equipment to be used at home is covered by insurance arrangements.

8.7 Council Tax and Business Rates

If a member of staff works at or from home, the accommodation within the home used as an ‘office’ may be liable to business rates, the remainder of the property will continue to be liable for council tax. The Valuation Office Agency (VOA) is an executive agency of HM Revenue and Customs. The VOA advise that in deciding whether or not part of a property should be liable to business rates there are a number of things which need to be

12 considered, including the extent and frequency of the non-domestic (Business) use of the room/s and any modifications made to the property to accommodate that use.

The Valuation Office Agency website, www.voa.gov.uk provides more information on this issue, together with examples of when business rates may apply. If a Trust Manager or employee requires further advice regarding this issue they should contact the local Valuation Office.

9.0 Review and Revision Arrangements

This policy will be reviewed on a regular basis by the Executive Management Team

10.0 Dissemination and Implementation

10.1 This document is on the intranet and website in the Document Store. Given the geographical spread of the Trust the only way to ensure staff access the current version is that it is only available on the intranet /website. 10.2 The procedural document is also noted on the monthly Team Brief informing the workforce that it has been approved. 10.3 The implementation of the Policy will be supported by all managers of staff, and other advisors within the Corporate support departments such as Human Resources, Performance and Information, Estates and Facilities etc.

11 Process for Monitoring Compliance and Effectiveness

11.1 The Information Governance Trust Action Group will conduct regular reviews of the use of Remote Working.

11.2 Audits will be undertaken to assess the use of the Authorisation Form for Remote Working at Appendix 1.

11.3 Incidents relating to remote working should be reported in the normal way and will be reviewed by the Information governance TAG.

12 Document control and archiving

12 1 This policy will be available on the intranet in read only format.

12.2 A central electronic read only version will be kept by the Integrated Governance Manager in a designated shared folder to which all Executive Management Team members and their administrative staff have access.

13 12.3 A central paper copy will be retained in the corporate library.

12.4 This policy will be retained in accordance with requirements for retention of non-clinical records.

12.5 Historic policies and procedures

 A central electronic read only version will be kept in a designated shared folder to which all Executive Management Team members and their administrative staff have access.

A central paper copy will be retained in the corporate library, clearly marked with the version number and date on which it was approved and date and title of the policy by which it was replaced

13 Associated documents

This document has been developed in line with guidance issued by the NHS Litigation Authority and with reference to model documents used in other trusts. It should be read in conjunction with:

 Guidance on Flexible Working Time

 Information Governance Policies (Data Protection, Confidentiality, Records Management, E-Mail, Information Security, Network security, Internet, Disposal of Confidential Waste)

 Health and Safety Policy

 Risk Assessment (Health and Safety) Policy

14 Appendix 1

SOUTH WEST YORKSHIRE PARTNERSHIP NHS FOUNDATION TRUST

Policy and Procedure on Remote Working

Authorisation Form for Remote (Including Home) Working

Name ______

Position ______

Practice ______

The following authorisation form is designed to ensure that Trust managers and staff have properly considered all issues relevant to remote working prior to an arrangement being agreed. If an application for Remote Working is received Trust managers must ensure that the requirements of the Flexible Working Regulations 2003 are met. Advice should be sought from an HR Manager if required.

General Issues

 Is the post suitable for home working, what impact will remote working have on the efficiency of the post holder, and the service?

 Does the post holder have the necessary skills and attributes to work remotely? For example ability to work independently with reduced contact with colleagues, self motivation, ability to meet deadlines without regular supervision?

 Are there any implications for colleagues, particularly those who the employee manages?

 Is a trial period appropriate? If so, length of period and review arrangements

 What hours will be worked remotely is this regular occurrence, daily/weekly/monthly etc?

 What facilities or equipment are required to support remote working, is there funding to support this?

15  How will equipment and records be stored in the home?

 How will communication between the manager and member of staff be maintained, the hours for telephone contact should be agreed. Managers and staff must ensure that the working time regulations are not breached by the Remote Working arrangement. For example, contracted hours will not change however adequate daily and weekly rest breaks must be maintained.

 If the application is in response to an employee’s ill health have the requirements of the Disability Discrimination Act been properly considered. Advice should be sought from an HR manager if needed.

 Have all health and safety issues been properly addressed? Trust managers must ensure that risk assessments have been completed for any home working arrangement in accordance with the Trust’s Risk Assessment Policy. For example, if the post holder will be spending prolonged periods of time working at a computer the Trust manager should arrange for an assessment under the Display Screen equipment regulations.

 Has the employee consulted their insurance company, mortgage holders and landlord if working from home? Note, failure to inform domestic insurers may result in home insurance cover rendered invalid.

 Have the Council Tax/Business Rates implications been properly considered?

Security, Data Protection and Confidentiality Issues

 Describe the data you intend to work on at home. Indicate the patient identifiers you will hold and any sensitive information such as clinical details and confidential management information.

 Any Trust business should be carried out on Trust IT equipment only.

 If an employee is working off line and saves information to a hard drive or device that device should be encrypted.

 What arrangements have been made to dispose of any paper printouts generated which hold person identifiable data.

16  Does the employee understand their responsibilities for the safe use of equipment, reporting any loss or damage and arrangements for return?

 Is the staff member aware that the transfer of identifiable information by e-mail must be done from www.nhs.net to www.nhs.net email accounts in order to ensure that it is encrypted.

 How will access to records in the event of the employees’ unavailability for whatever reason be maintained?

 How will an audit trail of the records be kept?

 What arrangements are in place to ensure the safe transportation of records to and from the home or other place of work? Will public transport need to be used?

 Where records and equipment are taken home after use for instance visiting a service users home or a clinic is the staff member aware that they must not be left in a car overnight and must be safely stored.

 What arrangements are in place to secure the records at the home whilst not in use?

 What arrangements are in place to protect the network from unauthorised access? For example by visitors, friends, family members etc

 How often will back-ups be carried out and where will the disks be stored (if not able to use Trust servers)

 Will the Trusts equipment and records be used in a ground floor room? If so what arrangements are in place to secure the room against theft and unauthorised access or casual access. In particular IT equipment, screens and paperwork should not be visible through the windows.

 Is the house in multiple occupancy? If so is the room where the records and equipment will be kept separately secured?

 Where necessary how will access to Trust documents be ensured – OoHs, when on leave etc. This may be necessary under the Data Protection or Freedom of Information Act.

 How will breaches be reported and monitored.

17  Any Trust related work and equipment, including any copies made and back-ups must be returned to the Trust in accordance with the contract should the employees employment cease for whatever reason.

 The employee must take responsibility for the physical safety of the records and equipment from environmental factors which may cause damage such as damp, smoke, pets etc. A risk assessment must be carried out.

As an employee of the South West Yorkshire Partnership NHS Foundation Trust you are bound by the Code of Conduct regarding the privacy of any individuals whose data you have access to. You will need to ensure the following:

 The data held and any equipment borrowed are protected by adequate security. This means that the PC should be located away from downstairs windows, the building should always be locked when unoccupied, family members and visitors should not have access to the data (use encryption on all files holding confidential data).

 You are being given access to the data at home for the above specified purpose only and the data must not be used for any other purpose.

 You should ensure that there is adequate virus protection on the PC you are using.

 Confidential data, laptops or other equipment must not be left in your car overnight.

 All electronic devices should be encrypted and password protected.

 In the case of home working that the Trust has access to the property when needed and you are aware that the Trust may require access to your property at short notice

18 I have read and understood the Trust policies in relation to Information Governance (which are Data Protection, Confidentiality, Records Management, E-Mail, IM & T Security, Network security, Internet, Disposal of Confidential Waste) and I understand that I am responsible for the equipment and information which I hold/use away from the work place.

Employee Details

Name: …………………………………… Job Title: ……………………………

Signed: …………………………………… Date: ……………………………

General Manager/Director Approval:

I am authorising the above to carry out work remotely for the purposes described below:

………………………………………………………………………………………………

Name: .... ……………………………. Position: ……………………………

Signature: ……………………………….. Date: ..…………………………..

Location: ………………………………………………………………………………

19 Appendix 2

Equality Impact Assessment Tool To be completed and attached to any procedural document when submitted to the appropriate committee for consideration and approval

Yes/No Comments 1. Does the policy/guidance affect one group less or more favourably than another on the basis of:

 Race NO

 Ethnic origins (including gypsies NO and travellers)

 Nationality NO

 Gender NO

 Culture NO

 Religion or belief NO

 Sexual orientation including NO lesbian, gay and bisexual people

 Age NO

 Disability - learning disabilities, NO physical disability, sensory impairment and mental health problems 2. Is there any evidence that some NO groups are affected differently? 3. If you have identified potential NO discrimination, are any exceptions valid, legal and/or justifiable? 4. Is the impact of the policy/guidance NO likely to be negative? 5. If so can the impact be avoided? N/A 6. What alternatives are there to N/A achieving the policy/guidance without the impact? 7. Can we reduce the impact by taking N/A different action?