How do we know what we don't know we don't know?

This week I was reviewing the advice that's going to be offered to organisations applying for project funding in a major investment programme. Naturally enough, the authors went into considerable depth to explain how Equality Impact Assessment would be considered as evidence that applicants were taking appropriate steps to ensure everyone benefitted from their proposals. We call this 'embedding' -- in other words, ensuring that new schemes consider the impacts on everyone from the outset -- even before the detailed design stage.

But it occurred to me that there is a danger in getting complacent about what any tool or process can do in these circumstances. In the computer business we used to call it GIGO -- garbage in, garbage out. An analytical tool is only as good as the information you feed into it.

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There are now three categories of Equality Duty on the statute book:

• There’s the Race Equality Duty, which has been with us since 2002.
  
• There’s the Disability Equality Duty, which took effect at the end of 2006
  
• And lastly (for the moment) there’s the Gender Equality Duty, which has been active since April 2007.

But things aren’t likely to stop there. It’s expected that the next Equality Bill will add further duties in relation to sexual orientation, age, and religion or belief

In the meantime it’s already regarded as good practice by many organisations to cover these areas in the same way as the statutory categories – within what’s usually called a ‘Single Equality Scheme’.

Legally, the statutory duties strictly apply only to public bodies. However, many private and voluntary sector organisations can also find the duties apply by proxy, as a result of institutions reviewing their purchasing and procurement arrangements.

In other words, if you’re a private sector company or a charity (say) – and if you want to contract to provide services on behalf of (let’s say) a local authority or a hospital – then it’s very likely that they’ll want to see evidence of the way in which you, too, promote equality. The same applies if you’re seeking project grants from (say) a Development Agency.

Some public bodies have been slow starters in this area.

In 2007 the old Commission for Racial Equality highlighted that none of the 43 NHS Trusts and Fire Services which it surveyed in Wales had properly fulfilled their responsibilities after five years. And there’s nothing to suggest that the situation elsewhere was much different, or that other kinds of organisations were faring any better on this or the other duties.

The new Equality and Human Rights Commission has signalled that it intends to use its’ teeth on this topic though – and the duties aren’t going to go away. Bit by bit, therefore, the culture of proactively ensuring and promoting equality will gradually pervade services everywhere, and people need to know how to apply the methodology effectively.

The steps involved are straightforward enough – at least on paper. They involve establishing appropriate (board level) accountability for the whole process; drawing up and publishing a scheme (or schemes) for what is going to be done; and then publishing an action plan (or plans).

Among the methods for doing all this in a systematic and auditable way is a process called Equality Impact Assessment. Such assessments, and many of the other stages too, require effective consultation.

The concept of Equality Impact Assessment is theoretically simple enough. It begins by an organisation asking itself whether or not an existing or proposed policy or process might impact different people disproportionately in some way or another.

To give some examples:

• A plan to move a health clinic to a new location might have implications for people who rely on public transport to get there.
  
• A plan to change the hours for the same clinic might affect a different group of people who need to collect children from school or nurseries – or it may deter others if they feel unsafe on the nearby streets.
  
• A move to weekend opening might be positive for some groups but it might have a disproportionately negative effect on others with families or particular religious needs.

Sometimes these implications may be obvious from our own experience, and it might be equally obvious how such a factor goes on to affect people of a particular gender or racial background, or with certain kinds of impairment.

Indeed it’s good practice to do a preliminary in-house sense check like this on every existing or proposed policy or service, as a way of deciding whether a more in-depth consideration is required. Most organisations simply wouldn’t have the resources to do a full analysis on everything.

But we all have limitations in our world view and experience. If you’re an affluent, educated, middle-manager who’s used to getting places by car, and has a partner to share in looking after children or elderly relatives then your understanding of the world and its practical limitations is likely to be rather different to a single parent, living on benefits, relying on public transport. You may simply not be able to see how an ostensibly reasonable provision might prevent such a person from using the service, or being able to apply for or sustain a job in your organisation.

Clearly impact assessment is only as effective as the limitations on your world view. This is why consultation is an important part of any assessment process – and at every stage.

But how do you know whether you’ve consulted widely enough? And how do you know whether the stakeholders you’ve spoken to have the breadth of knowledge and experience themselves to be reliable sources? This may be a particularly acute problem where the group concerned is unfamiliar or hard to locate.

Some communities should be relatively easy of course. If people form what we traditionally think of as a community – in other words they all live in one place – then there may be community groups you can approach. You could seek out spokespeople, or maybe you could use public meetings to ensure a variety of viewpoints are considered that way instead. Remember that people you encounter may themselves have a distorted or incomplete view of others in a different age group or social class.

Reaching people in a geographic community should not to be too difficult – you can put posters in shops and libraries, leaflets through doors or go to local social centres. (Though be careful to remember people who may be housebound, or have reading or language difficulties).

But some communities aren’t like that. Gay and lesbian people don’t all live in the same part of town, for instance. And beware of stereotypical assumptions about whether they all go to socialise in the same kind of pubs or clubs – or whether the needs and experiences of gay men equate with those of lesbian women, or bisexual people of either sex.

In these circumstances you may not be able to make direct approaches at all. Instead you might need to find a suitable organisation, such as a charity or voluntary group, to refer to for professional advice.

The same cautionary note applies here, of course – make sure you take steps to verify the expertise of organisations you speak to. How long have their experts worked with that community; how can they back up claims that they understand a broad cross-section of needs and experiences? Are they accountable to their community? You may need to go to several sources to be sure you have a balanced perspective.

And allow for the fact that, in spite of all these precautions, you and the stakeholders you consult may still get it wrong. You may miss an impact that nobody thought of. That’s why equality work can never be done-and-dusted. It’s always an iterative work in progress. The schemes and action plans you produce must be seen as working, living, documents which you revise continually on the basis of new experience.

If you’ve consulted well then it’s not a crisis to miss something out. The evidence that you’ve seriously tried to identify impacts is what matters; not the fact that you might have missed one despite your best endeavours.

But not consulting, or consulting poorly is far less forgivable. For that implies you simply don’t care that you don’t know what you don’t know.




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