Integrated Impact Assessment Guidance
Understanding Integrated Impact Assessment
Purpose of the Guidance
This guidance document has been designed to provide you with supporting information that supports the completion of the Integrated Impact Assessment (IIA) Template (separate document) and the formal IIA Training available. Please note that employees involved in the IIA process must have completed the IIA training and the mandatory corporate Equality and Diversity training, as a general understanding of equality and in particular the Protected Characteristics is required to ensure IIA is conducted effectively and appropriately.
For the purposes of this guidance the term IIA refers to both Integrated Relevance Assessment (IRA) (the screening aspect) and the full Integrated Impact Assessment process unless otherwise stated
What is Integrated Impact Assessment?
The purpose of Integrated Impact Assessment (IIA) is to ensure we comply with the law, taking account of equality, human rights, children's rights and socioeconomic disadvantage (poverty) implications when making decisions. It also ensures decision makers are fully informed, at a formative stage in the decision making process.
This process will allow us to critically assess whether a 'proposal' has wider impacts beyond its intended outcomes and if it impacts differentially on different groups in our communities.
The term 'proposal' is used throughout this guidance note and the template (separate document) and applies to policies, strategies, provisions, criteria, functions, practices, budget savings and activities, including the delivery of services.
Why is Integrated impact Assessment Required?
Assessing impact is an important part of the public sector's decision making process. It is important in developing any proposal to understand how the needs of different groups and the potential barriers they may face differ. IIA is a mechanism which enables you to consider the effects/needs/barriers and identify any potential adverse impacts of different groups. This process also gives us the opportunity to identify and highlight positive impacts.
It enables us to:
- Develop better policies and practices based on evidence
- Prevent or mitigate negative impacts
- Meet our legal requirements in terms of equality, Human Rights, Socioeconomic disadvantage and children's rights
- Be more transparent and accountable
When is Integrated Impact Assessment Required?
Assessing the impact is not an end in itself and should be an integral part of any 'proposal' development/change/revision/implementation etc. The regulations emphasise that it is the impact of applying a new or revised 'proposal' that must be assessed and equally we must actively consider how we could reduce inequality of outcome.
The assessment process must happen before a 'proposal' is finalised and as early in the development process as possible. The 'proposal' should be developed enough to enable an objective, reasonable and clear assessment to be undertaken. The assessment cannot be retrospective, or undertaken only near the end of the process, but instead should be seen as integral to the development process and able to inform the consultation process.
Assessing impact does not end with the introduction of the new or revised 'proposal'; it is important to monitor the actual impact of the 'proposal' as it is implemented, and revisit the assessment as part of any review. Therefore, assessment of impact should be considered as an ongoing, end-to-end process, from early discussions right through to the final decision about whether to go ahead with a 'proposal' or service change and beyond, to monitor the actual impact of the implementation.
In order to fulfil our general duty it is critical that all services conduct an IIA in the following circumstances;
- All significant policies, strategies, projects, service reforms/changes should have as a minimum an Integrated Relevance Assessment (IRA) built into the planning process.
- All budget options for each financial year will require as a minimum to be assessed for relevance.
- All reports to Council Executive require impacts relating to equality, human rights, children's' rights and socioeconomic disadvantage to be referenced, this should be a detailed summary included in the report and a copy of the IRA/IIA included in the background papers.
All changes to council policy or resources must be assessed for relevance and should be undertaken before any changes are agreed - this is a legal requirement.
N.B. It's important to consider cumulative impacts; this is especially relevant when you are making changes to a number of services across one or more service areas for example - making changes to policies for funding and delivering social care, day care, respite for carers and community transport.
Small changes in each of these policies may have a relatively minor effect on disabled and older people, but the cumulative effect of changes to these areas could have a significant effect on the participation in public life of these groups.
Who is responsible for completing an Integrated Impact Assessment?
The person or persons responsible for developing the 'proposal', or delivering a service are responsible for undertaking the assessment. The duty to complete the assessment cannot be delegated, therefore the person with the ultimate responsibility for the 'proposal' and its implementation must be aware that the IRA/IIA is being undertaken and must sign off the final document.
The IRA/IIA should be carried out as a group exercise. The group should include:
- those involved in developing the 'proposal' and bring together different perspectives on the subject matter
- those who will be involved or may ultimately implement the 'proposal'
- a person with an operational or front line perspective
- those with a particular knowledge of equality issues and
- it is good practice to invite an employee representative and/or HR colleague particularly where the proposal will have an impact on staffing arrangements or other workforce issues.
The group should consist of at least four people to bring a broad perspective, and include where possible people with protected characteristics where there are gaps in evidence.
Legal context - the Public Sector Equality Duty (PSED)
The public sector equality duty is set out in the Equality Act 2010 as the 'general equality duty'. The general equality duty requires public authorities, in the exercise of their functions, to have due regard to the need to:
- Eliminate unlawful discrimination, harassment and victimisation and other prohibited conduct;
- Advance equality of opportunity between those who share a protected characteristic and those who do not; and
- Foster good relations between those who share a protected characteristic and those who do not
The specific duties were created by secondary legislation in the Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012. The purpose of the specific duties in Scotland is to help those authorities listed in the Regulations in their performance of the general equality duty.
The Specific Duties (opens new window) in summary, require each listed authority to:
- report on mainstreaming the equality duty
- publish equality outcomes and report progress
- assess and review policies and practices
- gather and use employee information
- use information on members or board members gathered by the Scottish Ministers
- publish gender pay gap information
- publish statements on equal pay
- consider award criteria and conditions in relation to public procurement
- publish in a manner that is accessible