HSPOL16 Violence Aggression policy by Provide Community

Violence and Aggression Policy

Version: V7

Ratified By: Quality & Safety Committee

Date ratified: 27/06/2019

Job Title of Author: Head of Safety & Resilience

Reviewed by Sub Group or Expert Group: Health & Safety Group

Equality Impact Assessed by: Head of Safety & Resilience

1. Introduction

There has been a significant increase in recent years in the level of violence and abuse faced by employees, visitors and service users across the health and social care organisations.

Incidents have included significant injury to staff, damage to vital equipment and extreme verbal abuse and threats. Some of the perpetrators of violence and abuse are well known to staff and have persisted in this behavioural pattern during repeated visits to services.

There is therefore a widespread recognition amongst employees and management of a clear need to tackle such behaviour effectively and a belief that the fear of violence has the potential to seriously affect morale and the ability to recruit and retain staff.

Provide has a statutory obligation to provide a safe and secure environment for its staff and others as well as a duty to take all reasonable steps to protect and support its staff.

2. Policy

Provide will not condone or tolerate any aggressive, abusive or violent behavior towards our employees engaged in their lawful duties from any source - be they service users, visitors or even in incidences when staff verbally abuse fellow or ex colleagues. Violent or abusive behavior will not be tolerated and action will be taken to protect staff, service users and visitors.

The organisation is committed to providing a safe and secure environment in which antisocial behavior will not be tolerated. Provide will do anything within its power to support and protect its employees from becoming victims of aggressive, abusive or violent behavior.

The organisation is committed to supporting criminal proceedings and redress, where necessary and appropriate and withdrawing healthcare services to the perpetrator if an employee is subjected to unwarranted and unsolicited behavior and/or abuse.

Those service users who, in the expert judgement of the relevant clinician, such as an individual who becomes abusive as a result of an illness or injury and are not competent to take responsibility for their actions may not be subject to this procedure.

The use of this policy will apply to all violent/abusive visitors, relatives and service users, although some of the sanctions may only be applicable to those who are aged 16 or over. Furthermore, this policy will also apply to both current and ex-Provide employees.

The aim of the policy is to describe those behaviors, which are unacceptable, the sanctions available in the face of such behavior, and a mechanism whereby service users who are extreme or persistent in their unacceptable behavior can, as a last resort, be excluded from the service. Persistent unacceptable behavior refers to behavior both within one admission and/or over a number of separate attendances within period of the sanction.

In situations where current or ex-Provide employees engage in verbal or physical abuse to colleagues, mechanisms are in place to implement formal investigations in line with the Disciplinary and / or Whistle Blowing policy.

3. Responsibilities

Board

The responsibility for the provision of appropriate policies and procedures for all aspects of Health and Safety at work and the management of security rests initially with the Board.

Additionally, the Board will ensure through the line management structure that these policies andproceduresare appliedfullyandconsistentlyandthat allemployeesareaware of the standards and behaviours required under them.

Security Management Director

The Executive HR and OD Director is the nominated officer with the responsibility for security management, and will fulfil the function of the Security Management Director (SMD).

The Security Management Director will, through the delegated person (ASMS) oversee the introduction, operation, monitoring and evaluation of this policy to ensure comprehensive, fair and consistent application throughout the organisation.

The Security Management Director will, through the delegated person (ASMS) ensure the provision of training, guidance and support to line managers on the operation of this policy.

The Security Management Director will, through the delegated person/s ensure that queries in relation to this policy at a local level will be answered and ensure the policy is applied fairly and consistently throughout the Provide.

Accredited Security Management Specialist

Act as the organisation’s Accredited Security Management Specialist (ASMS), ensuring that the Secretary of State Directions and NHS Standard contract requirements are embedded.

Help to ensure that the organisation’s commitment to a Pro-Security culture is delivered including deterrence, prevention, detection, investigation, sanctions and redress, with emphasis on tackling violence and aggression, protection of assets, security of drugs and hazardous materials.

Continually critically evaluate security systems to ensure security is not compromised given the constantly changing and developing environment.

Act as the organisation’s expert advisor in relation to security requirements for redevelopment projects.

Be proactive in raising the awareness of all staff in security issues and liaising with training and development to ensure that appropriate Conflict Resolution Training is delivered to front line staff.

Ensure practical steps are taken to create the pro-security culture within Provide so that staff, contractors and service users accept responsibility for their personal security, and automatically detect or report breaches as they occur

Collect and collate evidence in line with judicial requirements for timely and appropriate case files for use by the Crown Prosecution Service and Legal Protection Unit and assist Counsel in court as required.

Ensure incident reporting is maintained and Datix incidents are actioned, reviewed or escalated at appropriate levels.

Undertake annual site surveys and assist in service security risk assessment as required.

Ensure robust systems are in place to control access to sensitive areas on sites.

Maintain and monitor the organisation’s lone working device system.

Lead on investigating serious verbal and physical assault, thefts, harassment & criminal damage incidents. Ensure the outcome of investigations, which may contain sensitive, contentious and complex information, is communicated to management and staff in a manner that is supportive and persuasive within a highly emotive atmosphere.

Work closely with and support the development of staff through specialist advice and training.

Assistant Directors and Team Managers

Assistant Directors and Team Managers are responsible for ensuring that this policy is applied within their Department.

Assistant Directors and Team Managers will ensure that employees are aware of and understand the requirements of the policy.

Assistant Directors and Team Managers will ensure that risk assessments take account of the risk of violence to staff and ensure that appropriate systems are in place to protect the safety of individuals.

Employees

Employees are responsible for reporting any incidents of violence or aggression through the incident reporting system (Datix), procedures are attached in Appendix 1.

If deemed necessary, contacts with service users in their own home, day Centre or residential home should be subject to a risk assessment which should include the risk of violence and/or aggression.

All employees (including those on honorary contracts and those working primarilyfor other organisation’s but on Provide premises) have a duty in the enactment of the policy.

Employees are responsible for complying with arrangements made under this policy.

Security is a management responsibility and the provision of a security service in no way relieves management at any level of its obligations to fulfil the stated purpose of security in the organisation.

All team managers have responsibility for security within their own units. Managers are required to exercise preventative aspects and to take appropriate action where necessary in respect of those who offend against the law, commit misconduct or other breach of security in contravention of the policies of the service.

4. Expected Standards of Behaviour

The following are examples of behaviours that are deemed to be wholly unacceptable on all premises and within any site where staff are delivering services:

• Excessive noise, e.g. loud or intrusive conversation or shouting

• Threatening or abusive language involving excessive swearing or offensive remarks

• Harassment of another

• Any derogatory, racial or sexual remarks

• Malicious allegations relating to members of staff, other service users or visitors

• Offensive sexual gestures or behaviours

• Abusing alcohol or drugs whilst in receipt of services (however, all medically identified substance abuse problems will be treated appropriately)

• Drug dealing

• Wilful damage to property

• Theft

• Threats or threatening behaviour

• Violence

• Failure to adequately control animals/pets

This is not an exhaustive list.

5. Sanctions

The following sanctions will apply to individuals whose behaviour is in contravention of the organisation’s expected levels of behaviour (Please see Section 4 above)

Service users/Visitors/Relatives

Service users, visitors and relatives who display any of the above behaviours will be asked to refrain from the behaviour or leave the premises; they will be given the opportunity to explain their actions. This will be considered a verbal warning.

Where a person’s behaviour threatens staff whilst delivering services within their home, concerns must be shared fully with the service user wherever possible and/or the offender and if the behaviour persists, the member of staff should withdraw from the premises immediately.

A plan to control exposure to this behaviour will be developed in consultation with the line manager and ASMS.

In situations where violence and aggression is experienced whilst a member of staff is working alone,thensystemsareinplaceregardingthismatter andfurtherreferenceshould be made to the Lone Working Policy.

Commitment to continuation of service user care will be maintained, at this stage.

Subsequent Failure to Comply

If there is a continued failure to comply with the required standard of behaviour then:

• If at any site, the offending individual should be asked to leave the property. If they refuse to leave, assistance should be sought by calling the police direct tosupport the ejection of the offending individual

• Whilst delivering services within a service user’s home, the member of staff will withdraw from the premises immediately

• The relevant Executive Director, Associate Director, Team Manager or Senior Nurse may decide to continue to exclude any individual removed from the premises or withhold treatment in the home and restrict their attendance only to specific times and if necessary, under escort

Process for Notification of Sanctions

Following any reported incident the immediate manager or department head will contact the Accredited Security Management Specialist (ASMS), giving full details of the incident and reporting via the Provide Incident Reporting Policy process.

The ASMS will then contact the service user, in agreement with the senior team manager to ensure all medical conditions are considered, and explain that his / her behaviour is unacceptable and inform them of the expected standards that must be observed in the future.

The ASMS will give a formal written warning about the possible consequences of such behaviours. This will consist of a standard letter agreed with the team leader and, where appropriate, the SMD. This will be considered the initial warning letter.

Staff will also be advised to complete the lone working risk assessment that can be found on SystmOne.

Implementation of the Acceptable Behaviour Agreement

Failure to refrain from the reported behaviour after receiving the initial warning letter will result in the application of what will hereafter be referred to as the Acceptable Behaviour Agreement (ABA) of Individuals that are Violent or Abusive.

This will be by way of a formal written letter including the ABA outlining the precise action required by both the service user and Provide The ABA will be issued by the ASMS and signed by the Security Management Director (SMD).

If a service user complies with the terms of the ABA he/she can expect the following:

• That clinical care will not be affected in any way

• That a copy of the ABA of individuals who are Violent or Abusive will be retained by the Accredited Security Management Specialist; copies will be kept on the service user’s notes indefinitely and also on the Datix record.

A system for flagging will be developed, and once in place, use of the ABA will be highlighted on this system.

• The relevant managers will be informed

• The organisation will fully investigate all valid concerns raised by the service user The ABA will be reviewed after one year and the outcome will be recorded on the service user’s notes.

Failure to Comply with the ABA

At the request of the relevant Assistant Director / Team Manager and that of the Executive Human Resources and Organisational Development Director (or their nominated deputies) failure to comply with the ABA will result in exclusion from services.

A letter, which includes the details of the reasons for withholding treatment will be issued by the ASMS and signed by the Security Management Director. This does not apply to service users under the age of 16.

On withholding care of any service user, Provide will notify the local Clinical Commissioning Group (CCG) of the reasons for the withholding of care and shall outline the action that has been taken to resolve prior to exclusion.

Exclusions from Provide will last one year, minimum, subject to alternative care arrangements being made; the provision of such arrangements will be pursued with vigour by the ASMS.

As part of the exclusion notice the service user/client will not attend any health body premises at any time except by prior appointments, where made through the provision of alternative care arrangements.

In event of anexcluded individualpresenting at Providepremisesfor emergencytreatment, personnel will adopt appropriate measures to ensure their safety. The individual will be treated, stabilised and where possible, they would then be transferred immediately to another facility if appropriate or discharged home.

Any person behaving in an unlawful manner will be reported to the police and Provide will seek the application of the maximum penalties and redress available in law. Provide will pursuethe prosecution of all perpetrators of crimeon or against provider services property, assets and staff.

Responsibility of the Local Clinical Commissioning Group

On notification from Provide of the withholding of care, the local Clinical Commissioning Group are responsible for ensuring that care is provided to the service user/s that have been excluded from Provide.

Care must be provided in environments where Provide staff will not be threatened or feel vulnerable by the actions of the excluded service user. All appropriate security arrangements must be considered in accordance with the local Clinical Commissioning Group security related policies.

Alternative care arrangements should be made within 4 weeks of notification of exclusion from the organisation. In most circumstances, a case conference should be held with all interested parties to provide the best alternative arrangements.

Staff / Ex-Employee’s

In situation where a current or ex-Provide employee carries out either verbally abuse or physical abuse an investigation will be launched by the ASMS. If further action is required then the matter will be discussed with both the immediate Team Manager and HR. If it is felt necessary, disciplinary proceedings will commence in line with the Disciplinary Policy.

In incidences where an ex-employee verbally abuses a member of staff or sends offensive messages through Social Media platforms, via mobile phone, in person or via the post investigations will commence and, if deemed suitable, sanctions will be imposed

6. Supported Living Team

Higher tolerance levels of violence and aggression can be expected within this service due to the complex needs of individuals, and the normal approach as outlined in Section 5 may not be a viable option.

With this in mind, incidents reported within the Supported Living Team are assessed on an individual basis and in consultation with the Supported Living Team Manager, the Team, the Assistant Director the service and the Head of Safety & Resilience.

Support plans will be reported and additional measures implemented if felt this is necessary. If required, the team will seek advice from physiatrist, social care and other medical professionals before any further sanctions are implemented.

In situations where behaviour significantly effects other individuals living in the properties, consideration will be given as to whether the site is the best place for resident and this will be review as above.

Ultimately, the safety of both our staff and other patients is of paramount importance and, if necessary, the organisation will seek to have individuals re-housed at alternative location more suitable for their individual supported needs.

7. Flow Chart of Action – Service Users /

Relatives

Incident of Physical / Non Physical Assault occurs

Verbal warning given to Service user/Visitor/Relative

If persists incident form produced and initial warning letter sent

If persists ABA established signed by SMD

If persists withholding of care, letter sent to service user explaining reasons

Local CCG identify alternative care arrangements within 4 weeks of being notified

Case reviewed after 12 months minimum

*Should the service user not follow any of the above sanctions Provide will apply for greater sanctions to be gained such as criminal / civil prosecution, in consultation with our Legal Team and the Police

8. Training – Conflict Resolution/Restraint Training

All staff undertake conflict resolution training and Ward based staff are required to undertake Restraint Training. Further training is also available once the needs of the individual have been identified through the Learning and Development Training Needs Analysis Matrix. Additionally, localised risk assessments also help to identify training requirements and these can be addressed by training for staff as appropriate for their role. Training is particularly important where there is limited supervision to control, guide and help in situations of uncertainty.

Training may be crucial to avoid panic reactions in unusual situations. Managers should ensure that members of staff are competent to deal with circumstances, which are new, unusual, or beyond the scope of training, for example, when to stop work and seek advice from a line manager and how to handle violence, aggression and/or abuse.

This training should include:

• Violence and Aggression policy and procedure

• Causes of violence

• Recognition of warning signs

• Interpersonal skills

• Managing aggression

• Resolving conflicts

• Assertion

• Breakaway techniques

• Management arrangements for dealing with violent incident

9. Reporting Arrangements

The Provide Manager on call will be informed, as soon as possible, of any untoward incidents.

All incidents of violence, aggression or abusive behaviour towards employees must be reported through our internal incident reporting system (Datix). This information will be forwarded to the appropriate bodies where shared care is in place (e.g. GP’s, Social Care and other Blue Light Services).

All incidents of violence, aggression or abusive behaviour towards employees that result in the employee being injured or unfit to work their normal work pattern for more than seven days, including days off, is required to be reported to the Health and Safety Executive (HSE) within ten days from the time of the incident. This will be achieved via an e mail to the Head of Safety & Resilience who will complete the necessary RIDDOR form (see Incident Reporting Policy).

10.Premises

Violent, Aggressive or Abusive Visitors

Provide reserves the right to refuse admittance to any person deemed undesirable due to their conduct by either words or actions and may be requested to leave by any staff member. Support for this exclusion can be sought from the police.

Violent, Aggressive or Abusive Behaviour towards Staff at Other Premises

Provide reserves the right to refuse treatment to any person deemed undesirable due to their conduct by either words or actions and any member of staff may refuse treatment/services and withdraw from the premises / home this includes acts of verbal or physical abuse carried out by relatives and or carer’s

Violence, aggression and abusive conduct extends also to behaviour demonstrated towards work colleagues.

Animals

It is not uncommon for service user’s to have pets (dogs, cats, snakes etc.) in their home. In the majority of cases the animals do not pose a threat to staff and staff are happy to treat service users with pets in the vicinity.

However as an organisation we respect the fact that some staff may feel uncomfortable about providing care with an animal in the same room. With this in mind, if staff feel uncomfortable then they have the right to request that the animal be securely placed in an alternative room whilst treatment is being carried out. If the service user refuses to do this, then staff have the right to refuse treatment.

11.Monitoring & Reporting

Provide is committed to reducing the incidents of violence, aggression or abusive behaviour towards employees. An annual ASMS work plan is submitted to the Board and a regular report will be prepared for the Safety & Quality Committee.

Provide will monitor the operation of this policy in order to:

• Measure its effectiveness

• Comply with Provide legal obligations

• Highlight practical issues and seek solutions

It will do this by:

• Receiving an Annual Report from the ASMS describing all activity relating to violence and aggression. This report will highlight good practice, concerns/problems, national developments and recommendations for improvements

• This report can form part of a larger report, for example, the Annual Quality & Safety report

• Monitoring incident rates throughout the year to identify trends

• Reviewing the staff survey annually

12.Review

The Accredited Security Management Specialist will review this policy on a regular basis, and at least bi-annually.

13.References

• NHS Counter Fraud & Security Management Service (CFSMS)

• Health & Safety at Work Act 1974

Appendix 1: Procedure for dealing with Service Users who are Violent or Abusive

Physical Assault

1. Should a physical assault occur this must be reported to the police immediately using 999 or 111

2. In addition to the Police, the Team Manager, ASMS and SMD must also be notified and an incident reporting process completed.

3. The ASMS will contact the victim to obtain all necessary information.

4. The ASMS will contact the Police to monitor the investigation and assist where required, including interviewing and obtaining supporting information.

5. Depending onthe outcome of the investigationthe ASMS maychoose to undertake an internal investigation.

6. The ASMS will contact the Human Resource Department to make them aware of the incident so that all the appropriate support and counselling is made available, if required by the member of staff.

7. The ASMS will inform the Executive Director of the incident and provide updates with regards to action taken or proposed.

8. The ASMS will ensure external agencies that provide a service (Social Care & Primary Care) tothe suspect are notified of the incident to prevent anyfurther crime or physical assault occurring.

9. At this stage Provide may choose to instigate an ABA without any prior warning issued to the individual to protect staff providing care.

10. In extreme circumstances the organisation may wish to withhold care of the suspect. The suspect must be notified in writing of this and the local Clinical Commissioning Group informed.

11. The local Clinical Commissioning Group should aim to provide alternative care arrangements within four weeks; this may be required sooner depending on the nature of the incident and the outcome of the case conference that should take place.

Non Physical Assault

1. Should a non-physical assault occur the suspect / service user may be given a verbal warning informing them that their behaviour is causing distress and is unacceptable. Dependent on the situation, if may be necessary for the suspect / service user to be sent an initial warning letter.

2. An incident report should be completed with all information (see Incident Reporting

3. & Management Policy) detailing that a verbal warning has been given and the ASMS informed.

4. Should the suspect/ service user continue to be non-physicallyaggressive afurther incident report should be completed as above, the ASMS should be notified immediately of this incident.

5. The ASMS will discuss the suspect/service user’s condition with the senior clinician / team leader and if felt appropriate an initial warning letter will be sent to the suspect/service users informing them of the possible consequences of their behaviour.

6. The suspect / service user will have the opportunity torespond to the letter in writing to the ASMS.

7. Should the suspect / service user not follow the advice of the initial warning letter and continue to be non-physically aggressive an ABA will be produced detailing the exact action required by both parties to continue to provide care.

8. The ABA will be agreed by all necessary parties (Team Manager / SMD & ASMS) and the suspect / service user will be required to sign up to the agreement. Should the suspect/service user not sign the agreement it will still stand as a formal agreement on the provision of their care.

9. If the suspect / service user fails to follow the clearly defined action within the ABA the organisation may choose to withhold care on the grounds of personal safety to their staff.

10. The SMD must notify the suspect/service user in writing that the clinical function being provided is being withdrawn. The letter must specifically detail the reasons for this withdrawal of care and the action that will be taken.

11. The SMD must immediately notify the local Clinical Commissioning Group of this decision.

12. The local Clinical Commissioning Group must arrange for a multi-disciplinary case conference to be held as a matter of priority to review the situation and make alternative arrangements to provide the required care.

13. The suspect / service user must be informed by the local Clinical Commissioning Group as soon as alternative care arrangements are finalised of the action that is required by him/her.

14. The alternative arrangements established by the Clinical Commissioning Group must be reviewed after 12 months.

15. The SMD should ensure that appropriate security arrangements are established to protect staff during the period that alternative care arrangements are being agreed. This should be for no longer than four weeks (extreme circumstances may require measures to be introduced sooner).

Appendix 2: Guidance on Dealing with Verbally Abusive Service Users

Most people who have worked in a job that involves dealing with the public either face to face or over the phone will have experienced an exchange with an abusive caller at some point or another. If you're ever face with such a scenario, maintain your professionalism and try to work toward a resolution.

Manner

Always maintain a polite and professional manner during any exchange with a service user. If you are verbally abused or exposed to personal attacks on your character, resist the urge to retaliate.

Explain

Ask the abusive service user / carer to calm down in a respectful manner and explain that you're there to help. Tell them it's going to be more difficult to resolve the issue while tempers are flared and that you're more likely to be able to address any concerns if any discussion is conducted in a civilised fashion.

Empathize

Tell your abusive service user that you can understand their frustration and that you would be upset if you were in their position, if they have a valid complaint.

Honesty

Be honest about what you can do. If you're unsure about how to deal with the caller, don't try to bluff your way through the situation. This will only serve to enrage the caller further and you could end up facing disciplinary action. Explain that you're unsure of how to deal with the situation and find out from your Manager or colleagues.

Refer to Policies

If a caller is complaining about an issue respectfully refer them to our Complaint Team.

Escalate

If it becomes clear that you are unable to deal with an abusive caller effectively, don't be afraid of passing the problem on to your Manager or a colleague who is more experienced at negotiating with angry callers.

Issue a Warning

If your caller repeatedly uses abusive language and / or threatens you, advise them that you do not have to, nor will you, tolerate being spoken to in such a manner. Explain again that you are there to help, but warn them that you will terminate the call if you're on the phone or call the Police if you're discussing the situation in person.

Silent Treatment

Don't try to talk over or interrupt your abusive caller when they are in mid-flow. This is only likely to make the caller angrier. Let them finish what they are saying. If this involves a long, drawn-out rant, so be it. Remain silent for a few seconds after they have run out of things to say and then state your position. If the caller interrupts, tell them that you have listened carefully and would be grateful if they could extend you the same courtesy.

State Your Position

If the discussion is going nowhere, state your position firmly but politely and advise your caller to make a complaint.

Terminate the Conversation

If all else fails and you're unable to get through to your abusive caller, end the discussion. If you're on the phone, explain politely that you feel you can go no further with the conversation and that you're going to hang up. If you're dealing with the service user face to face, ask them to leave your premises.

EQUALITY IMPACT ASSESSMENT TEMPLATE: Stage 1: ‘Screening’

Name of project/policy/strategy (hereafter referred to as “initiative”):

Violence and Aggression Policy

Provide a brief summary (bullet points) of the aims of the initiative and main activities:

The aim of the policy is to describe those behaviour, which are unacceptable, the sanctions available in the face of such behaviour, and a mechanism whereby service users who are extreme or persistent in their unacceptable behaviour can, as a last resort, be excluded from the service.

Project/Policy Manager: Head of Safety & Resilience Date: March 2019

This stage establishes whether a proposed initiative will have an impact from an equality perspective on any particular group of people or community – i.e. on the grounds of race (incl. religion/faith), gender (incl. sexual orientation), age, disability, or whether it is “equality neutral” (i.e. have no effect either positive or negative). In the case of gender, consider whether men and women are affected differently.

Q1. Who will benefit from this initiative? Is there likely to be a positive impact on specific groups/communities (whether or not they are the intended beneficiaries), and if so, how? Or is it clear at this stage that it will be equality “neutral”? i.e. will have no particular effect on any group.

Neutral

Q2. Is there likely to be an adverse impact on one or more minority/under-represented or community groups as a result of this initiative? If so, who may be affected and why? Or is it clear at this stage that it will be equality “neutral”?

Neutral

Q3. Is the impact of the initiative – whether positive or negative - significant enough to warrant a more detailed assessment (Stage 2 – see guidance)? If not, will there be monitoring and review to assess the impact over a period time? Briefly (bullet points) give reasons for your answer and any steps you are taking to address particular issues, including any consultation with staff or external groups/agencies.

Neutral

Guidelines: Things to consider

• Equality impact assessments at Provide take account of relevant equality legislation and include age, (i.e. young and old,); race and ethnicity, gender, disability, religion and faith, and sexual orientation.

• The initiative may have a positive, negative or neutral impact, i.e. have no particular effect on the group/community.

• Where a negative (i.e. adverse) impact is identified, it may be appropriate to make a more detailed EIA (see Stage 2), or, as important, take early action to redress this – e.g. by abandoning or modifying the initiative. NB: If the initiative contravenes equality legislation, it must be abandoned or modified.

• Where an initiative has a positive impact on groups/community relations, the EIA should make this explicit, to enable the outcomes to be monitored over its lifespan.

• Where there is a positive impact on particular groups does this mean there could be an adverse impact on others, and if so can this be justified? - e.g. are there other existing or planned initiatives which redress this?

• It may not be possible to provide detailed answers to some of these questions at the start of the initiative. The EIA may identify a lack of relevant data, and that data-gathering is a specific action required to inform the initiative as it develops, and also to form part of a continuing evaluation and review process.

• It is envisaged that it will be relatively rare for full impact assessments to be carried out at Provide. Usually, where there are particular problems identified in the screening stage, it is envisaged that the approach will be amended at this stage, and/or setting up a monitoring/evaluation system to review a policy’s impact over time.

EQUALITY IMPACT ASSESSMENT TEMPLATE: Stage 2:

(To be used where the ‘screening phase has identified a substantial problem/concern)

This stage examines the initiative in more detail in order to obtain further information where required about its potential adverse or positive impact from an equality perspective. It will help inform whether any action needs to be taken and may form part of a continuing assessment framework as the initiative develops.

Q1. What data/information is there on the target beneficiary groups/communities? Are any of these groups under- or over-represented? Do they have access to the same resources? What are your sources of data and are there any gaps?

Q2. Is there a potential for this initiative to have a positive impact, such as tackling discrimination, promoting equality of opportunity and good community relations? If yes, how? Which are the main groups it will have an impact on?

Q3. Will the initiative have an adverse impact on any particular group or community/community relations? If yes, in what way? Will the impact be different for different groups – e.g. men and women?

Q4. Has there been consultation/is consultation planned with stakeholders/ beneficiaries/ staff who will be affected by the initiative? Summarise (bullet points) any important issues arising from the consultation.

Q5. Given your answers to the previous questions, how will your plans be revised to reduce/eliminate negative impact or enhance positive impact? Are there specific factors which need to be taken into account?

Q6. How will the initiative continue to be monitored and evaluated, including its impact on particular groups/ improving community relations? Where appropriate, identify any additional data that will be required.

Guidelines: Things to consider

• An initiative may have a positive impact on some sectors of the community but leave others excluded or feeling they are excluded. Consideration should be given to how this can be tackled or minimised.

• It is important to ensure that relevant groups/communities are identified who should be consulted. This may require taking positive action to engage with those groups who are traditionally less likely to respond to consultations, and could form a specific part of the initiative.

• The consultation process should form a meaningful part of the initiative as it develops, and help inform any future action.

• If the EIA shows an adverse impact, is this because it contravenes any equality legislation? If so, the initiative must be modified or abandoned. There may be another way to meet the objective(s) of the initiative.

Further information:

Useful Websites www.equalityhumanrights.com Website for new Equality agency www.employers-forum.co.uk – Employers forum on disability www.disabilitynow.org.uk – online disability related newspaper www.efa.org.uk – Employers forum on age

EQUALITY IMPACT ASSESSMENT TEMPLATE: Stage One: ‘Screening’