Part
1 – The Public Sector Equality Duty and Equality
Impact Assessments (EIA)
1.1
The Council must have
due regard to its Public Sector Equality Duty when making all
decisions at member and officer level. An EIA is the best
method by which the Council can determine the impact of a
proposal on equalities, particularly for major decisions. However,
the level of analysis should be proportionate to the relevance of
the duty to the service or decision.
1.2
This is one of two forms that the County Council uses for Equality
Impact Assessments, both of which are available on the intranet.
This form is designed for any proposal, project or service. The
other form looks at services or projects.
1.3
The Public Sector Equality Duty (PSED)
The public sector duty is set out
at Section 149 of the Equality Act 2010. It
requires the Council, when exercising its functions, to have
“due regard‟to the need to
- Eliminate discrimination,
harassment, victimisation and any other conduct that is prohibited
under the Act.
- Advance equality of opportunity
between persons who share a relevant protected characteristic and
persons who do not share it;
- Foster good relations between
persons who share a relevant protected characteristic and persons
who do not share it. (see below for “protected
characteristics”
These are sometimes called
equality aims.
1.4
A “protected characteristic‟ is defined in the Act
as:
- age;
- disability;
- gender reassignment;
- pregnancy and
maternity;
- race (including ethnic or national
origins, colour or nationality)
- religion or belief;
- sex;
- sexual orientation.
Marriage and civil partnership are
also a protected characteristic for the purposes of the duty to
eliminate discrimination.
The previous public
sector equalities duties only covered race, disability and
gender.
1.5
East Sussex County Council also considers the following additional
groups/factors when carry out analysis:
- Carers – A carer spends a
significant proportion of their life providing unpaid support to
family or potentially friends. This could be caring for a relative,
partner or friend who is ill, frail, disabled or has mental health
or substance misuse problems. [Carers at the Heart of 21stCentury
Families and Communities, 2008]
- Literacy/Numeracy
Skills
- Part time workers
- Rurality
1.6
Advancing equality (the second of the equality aims)
involves:
- Removing or minimising
disadvantages suffered by people due to their protected
characteristic
- Taking steps to meet the needs of
people from protected groups where these are different from the
needs of other people including steps to take account of disabled
people’s disabilities
- Encouraging people from protected
groups to participate in public life or in other activities where
their participation in disproportionately low
NB Please note that,
for disabled persons, the Council must have regard to the
possible need for steps that amount to positive discrimination, to
“level the
playing field” with non-disabled persons, e.g. in accessing
services through
dedicated car parking spaces.
1.6
Guidance on Compliance with The Public Sector Equality Duty (PSED)
for officers and decision makers:
1.6.1 To comply with
the duty, the Council must have “due regard” to the
three equality aims set out above. This means the PSED must
be considered as a factor to consider alongside other relevant
factors such as budgetary, economic and practical
factors.
1.6.2 What regard is
“due” in any given case will depend on the
circumstances. A proposal which, if implemented, would have
particularly negative or widespread effects on (say) women, or the
elderly, or people of a particular ethnic group would require
officers and members to give considerable regard to the equalities
aims. A proposal which had limited differential or
discriminatory effect will probably require less
regard.
1.6.3 Some key
points to note :
- The duty is regarded by the Courts
as being very important.
- Officers and members must be aware
of the duty and give it conscious consideration: e.g. by
considering open-mindedly the EIA and its findings when making a
decision. When members are taking a decision,this duty can’t
be delegated by the members, e.g. to an officer.
- EIAs must be evidence
based.
- There must be an assessment of the
practical impact of decisions on equalities, measures to avoid or
mitigate negative impact and their effectiveness.
- There must be compliance with the
duty when proposals are being formulated by officers and by members
in taking decisions: the Council can’t rely on an EIA
produced after the decision is made.
- The duty is ongoing: EIA’s
should be developed over time and there should be evidence of
monitoring impact after the decision.
- The duty is not, however, to
achieve the three equality aims but to consider them – the
duty does not stop tough decisions sometimes being
made.
- The decision maker may take into
account other countervailing (i.e. opposing) factors that may
objectively justify taking a decision which has negative impact on
equalities (for instance, cost factors)
1.6.4 In addition to
the Act, the Council is required to comply with any statutory Code
of Practice issued by the Equality and Human Rights Commission. New
Codes of Practice under the new Act have yet to be published.
However, Codes of Practice issued under the previous legislation
remain relevant and the Equality and Human Rights Commission has
also published guidance on the new public sector equality
duty.
2.1
What is being assessed?
a)
Proposal or name of
the project or service. What is
being assessed–proposal, strategy or policy?
The proposed reduction to The Keep
public opening hours
b)
What is the main
purpose or aims of proposal, project or service?
Give a
brief description of the main aims.
The purpose of the proposal is to
ensure the medium-term financial sustainability of The Keep in
light of the financial pressures facing partners.
The proposal aims to reduce
running costs by reducing public opening hours whilst ensuring
continued public access to the collections held at the archive
centre, in line with our statutory responsibility. The Keep is
currently open to the public five days per week for a total of 36
hours. By shortening opening hours each day, it would be possible
to continue to provide access to The Keep five days per week.
Overall it is proposed that opening hours are reduced by 12 hours
(33%), as detailed below:
|
|
Current
|
Proposed
|
|
Monday
|
Closed
|
Closed
|
|
Tuesday
|
9.30am – 5pm
|
10am – 4pm
|
|
Wednesday
|
10am – 5pm
|
10am – 4pm
|
|
Thursday
|
9.30am – 5pm
|
10am – 1pm
|
|
Friday
|
9.30am – 5pm
|
10am – 4pm
|
|
Saturday
|
9.30am – 4pm
|
10am – 1pm
|
|
Sunday
|
Closed
|
Closed
|
|
Total
|
36 hours p/w
|
24 hours p/w
|
Opening hours of Accredited
Archive Services (AAS) vary considerably across the country.
An analysis of the average weekly opening hours of many AAS shows
that most are open for an average of 30 – 40 hours per
week. The proposed 24 hours per week of public opening time
at The Keep would, however, be more than the average weekly opening
hours of the Shropshire Archives, Denbighshire Archive Service,
Warwickshire County Record Office, Bolton Archives and Local
Studies Service, and the Cumbria County Council Record
Office. The Northumberland Archives are currently open 24
hours per week on average. For comparison the West Sussex Record
Office is open for 36.25 hours per week, the Surrey History Centre
for 36.75 hours per week and the Kent History and Library Centre
for 40 hours per week.
c)
Manager(s) and
section or service responsible for completing the
assessment.
Explain
why the members of the impact assessment team were selected, e.g.
the knowledge and experience they bring to the process
Jack Pierce, Principal Customer
Services Officer, Communities, Economy and Transport
Department
2.2
Who is affected by the proposal, project or service? Who is it
intended to benefit and how? Who are
the main stakeholders in relation to this proposal, strategy or
policy? Service users/carers/employees? What outcomes would other
stakeholders want from this proposal, strategy or
policy?
The Keep is an archive centre that
offers free access to anyone wishing to make use of it. The
proposed reduction in opening hours has the potential to affect
anyone who chooses to visit The Keep.
In 2019, there were 6,638 visits
to The Keep by members of the public to view items from the
collections. Due to the impact upon typical visits to The Keep
because of the Covid-19 pandemic, we have not revised this
statistic from a more recent period.
The Keep partnership also open the
facility for pre-booked events including talks and workshops. These
pre-booked events could continue outside of public opening hours
and so would not be affected by the proposed changes to public
opening hours.
2.3
How is, or will, the proposal, project or service be put into
practice and who is, or will be, responsible for it?
Who
defines or defined the proposal, strategy or policy? Who implements
the proposal, strategy or policy? How does the Council interface
with other bodies in relation to the implementation of this
proposal, strategy or policy? If external parties are involved,
then what are the measures in place to ensure that they comply with
the Council’s Equality Policy?
Public consultation on the
proposals was held from 14 September to 25 October 2020. The
results of the consultation have informed this EqIA.
Subject to the review of the
consultation feedback and approval by all three partners, the new
opening hours would be introduced from April 2021.
The members of The Keep Board will
be jointly responsible for the proposed changes to opening hours,
with the implementation led by the Team Manager, Archive Services
and The Keep.
2.4
Are there any partners involved? E.g. NHS Trust,
voluntary/community
organisations, the private sector? If yes, how are partners
involved?
The Keep partnership consists of
East Sussex County Council, Brighton and Hove City Council and the
University of Sussex who work collaboratively to collect and
maintain archives and provide public access to archives in their
collections.
The Keep Management Team and The
Keep Board is comprised of representatives of the three partner
organisations.
Sussex Family History Group and
University of Sussex lease rooms on site. The use of these rooms
would not be affected by the changes to public opening hours; the
building will remain open to volunteers, lease holders and staff
six days/week with staff on site from 8am to 6pm.
2.5 Is
this proposal, project or
service affected by legislation,
legislative change, service review or strategic planning
activity?
There is a range of
legal obligations and constraints which the authorities have
inherited by virtue of the nomination of The Keep as a Local Place
of Deposit by the National Archives, through its appointment as a
Diocesan Record Office by the Diocesan bishop and as a manorial
repository by the Master of the Rolls. In addition, ESRO fulfils
the legal duties of ESCC, as well as BHCC and constituent district
and parish councils who have chosen to discharge their duties to
hold local government records relating to East Sussex and Brighton
and Hove.
The public
consultation and final EqIA have been undertaken before The Board
consider approving any changes to opening hours. This will ensure
that a clear evidence base is provided, our statutory
responsibilities are adhered to and that we continue to offer
reasonable public access to records.
2.6
How do people
access or how are people referred to your
proposal, project
or service? Please explain fully.
Is it a
public service accessed by all, e.g. Bus Service, or is there a
referral method? If so, what is this?
The Keep is a public facility open
to any member of the public wishing to make use of it.
2.7
If there is a referral method how are people assessed to use
the proposal, project or
service?
Please explain fully. Consider
if an assessment is carried out, where and how does this take
place?
N/A
2.8
How, when and where is your proposal, project or
service provided? Please explain
fully. Is it a
public or dedicated service? Where and how is it
provided?
Please refer to the table in 2.1b)
above which shows the current and proposed public opening hours for
The Keep. The location and all
other aspects of the service will remain unchanged.
Part 3
– Methodology, consultation, data and research used to
determine impact on protected characteristics.
To conduct
the assessment, you will need information about service users and
staff. This section is to help you identify the sort of
information that will be needed to help you assess whether there
may be barriers to different equality groups who use your proposal,
strategy or policy.
3.1List all examples of quantitative
and qualitative data or any consultation information available that
will enable the impact assessment to be
undertaken.. Please
note that both Census data and Staff Survey should be
considered. In some cases data may not exist or be available
and you may therefore have to undertake additional research. If
data is not available please state.
|
Types of evidence identified as relevant have X marked
against them
|
|
|
Employee Monitoring
Data
|
|
Staff Surveys
|
|
X
|
Service User Data
|
|
Contract/Supplier Monitoring
Data
|
|
X
|
Recent Local
Consultations
|
|
Data from other agencies, e.g.
Police, Health, Fire and Rescue Services, third sector
|
|
|
Complaints
|
|
Risk Assessments
|
|
X
|
Service User Surveys
|
X
|
Research Findings
|
|
X
|
Census Data
|
X
|
East Sussex
Demographics
|
|
|
Previous Equality Impact
Assessments
|
|
National Reports
|
|
|
Other organisations Equality
Impact Assessments
|
|
Any other evidence?
|
3.2
Evidence
of complaints against the proposal, project or service on grounds
of discrimination. Is there
any evidence of complaints either from service users or staff
(grievance) as to the implementation of the proposal strategy or
policy and its delivery on the protected
characteristics?
3.3
This is the final revised and
updated EqIA following the recent public consultation regarding
these proposals. No complaints on grounds of discrimination have
been received to date on our proposals, or previously regarding
opening hours at The Keep.
3.3 If you carried out any
consultation or research on the proposal, project or
service explain what consultation has been
carried out.
In advance of the public
consultation, the partnership collected data during the second half
of 2019 in relation to the nature of customers’ visits to The
Keep via a customer survey. This survey data gave the project team
and the Board an understanding of the likely impact on customers of
a reduction in opening hours and enabled consideration of any
potential mitigation that may be required, prior to an opening
hours proposal being put to public consultation.
In addition, staff completed a
desk survey during the same period to provide insight into the
nature of interactions between staff and users during a typical
week. The analysis of both of these surveys assisted the formation
of the proposal which the Board agreed could be put to public
consultation.
The proposals were subject to
public consultation from 14 September to 25 October 2020. During
the consultation period, 277 customers provided their
feedback.
The public consultation
questionnaire was designed to inform understanding of who our
customers are, the timing, frequency and duration of their visits
and what activities and tasks they are predominantly completing
when visiting The Keep, as well as whether the proposed change to
opening hours would impact on their ability to visit The
Keep.
3.4What does the consultation,
research and/or data indicate about the positive or negative impact
of the proposal, project or service? Does any
of the evidence show that there is a negative impact on one or more
group of people? This will need to be ncluded/expanded on in Part
4.
3.5
The results of the consultation
survey will inform the Board’s decision regarding an
alteration to opening hours. Following analysis of both the
customer survey during 2019 and the feedback provided during the
public consultation, it is not anticipated that the reduction in
opening hours will have a disproportionately negative impact on any
of the existing users as access to The Keep five days per week will
be maintained. Customers will also still be able to access a range
of materials via The Keep’s
websiteand the partnership is committed
to the development and improvement of The Keep’s digital
offer.
4.1
Age: Testing of disproportionate, negative, neutral or positive
impact. Consider
both issues affecting older and younger people. An age group
includes people of the same age and people of particular age
ranges. An age group would include "over sixties" or twenty year
olds.
a)
How is this
protected characteristic reflected in the
County/District/Borough?
|
Protected
characteristic
|
East
Sussex
|
Eastbourne
|
Hastings
|
Lewes
|
Rother
|
Wealden
|
Brighton
& Hove
|
|
|
|
|
|
Total
|
Total
population, 2018
|
554,590
|
103,160
|
92,855
|
102,744
|
95,656
|
160,175
|
290,395
|
|
|
Age
|
Population,
0-15 (%) - 2018
|
17.1
|
17.3
|
18.6
|
17.3
|
14.9
|
17.1
|
15.6
|
|
|
Population,
16-64 (%) - 2018
|
57.3
|
57.8
|
61.7
|
57.1
|
53.2
|
56.9
|
71.1
|
|
|
Population,
65+ (%) - 2018
|
25.7
|
24.9
|
19.8
|
25.5
|
31.9
|
25.9
|
13.3
|
|
b)
How is this
protected characteristic reflected in the population of those
impacted by the proposal, project or service?
|
Age
|
Number
of respondents
|
Percentage
|
|
Under
18
|
0
|
0%
|
|
18
– 24
|
0
|
0%
|
|
25
– 34
|
12
|
4.33%
|
|
35
– 44
|
20
|
7.22%
|
|
45
– 54
|
30
|
10.83%
|
|
55
– 64
|
82
|
29.60%
|
|
65-74
|
95
|
34.30%
|
|
75+
|
25
|
9.03%
|
|
Prefer
not to say
|
4
|
1.44%
|
|
No
answer
|
29
|
3.25%
|
|
Total
|
277
|
100%
|
Respondents to
the opening hours consultation from 14 September to 25 October
2020.
c)
Will people with the protected characteristic be
more affected by the proposal, project or service than those in the
general population who do not share that protected
characteristic?
You will
need to refer to evidence gathered through monitoring and
consultation in conjunction with the population statistics in a).
Do you have any data available to show who will be affected by this
proposal, policy or strategy? Or is this unknown due to there being
no data available?
The results of our surveys show
that of customers to The Keep are aged 65 and over (43.3%) in
addition to the 29.6% of consultees who stated they were between 55
and 64 years old. These groups therefore have the potential to be
more affected by the proposals than those in the general
population. However, people aged 55 and older are more likely to be
retired and therefore have the flexibility to travel at alternative
times of the day, within the proposed new opening hours. In
response to the question about employment status, 47.3% of
consultees indicated that they consider themselves to be retired
whether receiving a pension or not.
d)
What is the
proposal, project or service’s impact on different ages/age
groups? Whilst
there may be positive and neutral factors of the proposal, policy
or strategy, which should be set out here do not try to conceal
negative impacts by only highlighting the positive
impacts
The impact of the proposals on
different age groups is largely dependent on the flexibility they
have to travel at different times of the day. Retired people are
likely to have greater flexibility as to the time of day they visit
The Keep.
The times of day of customer
interactions with staff and duration of visits of existing users of
The Keep have been analysed and this has been considered in the
proposed, reduced opening hours, to enable people to continue to
access the centre when it is most convenient for the majority of
users.
People aged under 65 are more
likely to work full time and therefore access The Keep on
Saturdays. This age group could therefore be more impacted by the
proposed closure on Saturday afternoons. However, our survey data
shows that Saturdays are currently the least popular day with on
average only 16 visitors per day, compared to between 27 and 35 on
other days.
e)
What actions are
to/or will be taken to avoid any negative impact or to better
advance equality? Focus on
evidence of disproportionate impact i.e. where a decision affects a
protected group more than the general population. For example Older
people are more likely to be using day services and so decisions
affecting the provision of these services will have a greater
impact on Older people. State how the protected group will be
affected e.g. accessibility of a service? Impact on standard of
living/education/leisure time etc.?
For the protected characteristic
of age, we have identified that people aged under 65 in full time
employment have the potential to be more impacted by the changes
than those who have the flexibility to travel at different times of
the day. It is proposed to continue to provide public access to The
Keep on Saturday mornings to provide a range of times and days that
visitors can engage with services on site.
f)
Provide details of
the mitigation
The Keep will continue to be open
to the public five days per week, including Saturday
mornings.
In addition, The Keep’s
website enables customers to plan their
visit to The Keep in advance as well as access some services
without the need to visit The Keep building. The website
is available 24 hours
per day from anywhere with an internet connection. Customers can browse the catalogue,
order digital or print copies and purchase research services, view
the events programme and book and pay for tickets for events. 92%
of consultees have internet access on a device that they own
(laptop/PC, mobile phone or tablet).
Customers can
register online rather than coming into the centre. This allows
them to order documents they source on the catalogue (which they
can then view at The Keep in hard copy), create wish-lists and save
their searches for use another time.
Support is available
if customers need help using the website. “Welcome
Wednesday” sessions are run once a month which are supported
by volunteers and help new users get to know the set up and
collections
and these
will re-start when Covid-related restrictions permit.
How-to notes
are available on the website, and in paper form
at The Keep. These will be improved to make them more user-friendly
and in plain English. Volunteer computer buddies will be recruited
to support customers with low IT levels when Covid-related
restrictions permit.
g)
How will any
mitigation measures be monitored? How will
the effectiveness of mitigation be monitored?
We will continue to record visitor
numbers at The Keep to monitor whether they affected by the
changes.
We will continue to record visits
to our website, to monitor whether they increase following the
reduction in opening hours.
Customer feedback will continue to
be monitored to inform future improvements to the website and
on-site services.
4.2
Disability: Testing of disproportionate, negative, neutral or
positive impact.
Consider
different disabilities:
Physical
Impairment, such as using arms or mobility issues.
Sensory
Impairment, such as being blind or having a serious visual
impairment
Mental
Health Condition, such as depression or schizophrenia
Learning
Disability/Difficulty, such as Down’s Syndrome or
dyslexia
a)
How is this
protected characteristic reflected in the County
/District/Borough?
|
Protected
characteristic
|
East
Sussex
|
Eastbourne
|
Hastings
|
Lewes
|
Rother
|
Wealden
|
Brighton
& Hove
|
|
|
|
|
|
Total
|
Total
population, 2018
|
554,590
|
103,160
|
92,855
|
102,744
|
95,656
|
160,175
|
290,395
|
|
|
Disability
|
Limiting
long-term illness, 2011
|
107,145
|
20,831
|
19,956
|
19,054
|
21,242
|
26,062
|
44,569
|
|
|
Projected
LLTI 2017
|
114,741
|
22,407
|
20,822
|
20,400
|
21,744
|
29,367
|
N/A
|
|
|
Projected
disability, 2017
|
98,608
|
19,414
|
17,419
|
17,578
|
18,904
|
25,293
|
N/A
|
|
b)
How is this
protected characteristic reflected in the population of those
impacted by the proposal, project or service?
|
Disability
|
Number
of respondents
|
Percentage
|
|
Yes
|
36
|
13.00%
|
|
No
|
219
|
79.06%
|
|
Prefer
not to say/no answer
|
22
|
7.94%
|
|
Total
|
277
|
100%
|
Respondents to
the opening hours consultation from 14 September to 25 October
2020
Type
of disability recorded by respondents to the public consultation
2020
|
|
Number
of respondents
|
Percentage
|
|
Physical
impairment
|
17
|
29.31%
|
|
Sensory
impairment
|
5
|
8.62%
|
|
Long
standing illness or health condition
|
18
|
31.03%
|
|
Mental
health condition
|
8
|
13.79%
|
|
Learning
disability
|
5
|
8.62%
|
|
Prefer
not to say/other/no answer
|
4
|
6.90%
|
|
Other
|
1
|
1.73%
|
|
Total
|
58
|
100%
|
Respondents to
the opening hours consultation from 14 September to 25 October
2020
c)
Will people with the protected characteristic be
more affected by the proposal, project or service than those in the
general population who do not share that protected
characteristic? You will
need to refer to evidence gathered through monitoring and
consultation in conjunction with the population statistics in a).
Do you have any data available to show who will be affected by this
proposal, policy or strategy? Or is this unknown due to there being
no data available?
The data from the public
consultation shows that 13% of respondents consider themselves to
have a disability.
The proposed reduced opening hours
have the potential to negatively impact those people with certain
disabilities who as a result of those disabilities have to rely on
a personal helper who is not available within the proposed reduced
opening hours.
d)
What is the
proposal, project or service’s impact on people who have a
disability? Whilst
there may be positive and neutral factors of the proposal, policy
or strategy, which should be set out here do not try to conceal
negative impacts by only highlighting the positive
impacts
The proposed changes have been
developed to minimise the impact for current visitors to The Keep.
This has been done by opening only 30 minutes later on three days
and closing only one hour earlier, with the exception of Thursday
and Saturday afternoons when the building would be closed from 1pm.
Please refer to the able of current and proposed opening hours in
2.1 b).
Where consultees stated they would
not be able to visit the Keep within the proposed public opening
hours, they were asked to give reasons. Within these responses
there was not any specific or direct reference to a user’s
disability.
In view of consultation feedback
and as a result of the way the proposed reduction in hours is
spread across five days, it is not anticipated that the proposed
reduction would disproportionately negatively impact disabled
customers.
However, any disabled customers
who are unable to visit The Keep in the reduced opening hours due
to the unavailability of their personal helper or accessible
transport may be more reliant on the website, research and
reprographics services, or be able to visit The Keep less
frequently.
e)
What actions are
to/ or will be taken to avoid any negative impact or to better
advance equality? Focus on
evidence of disproportionate impact i.e. where a decision affects a
protected group more than the general population. For example
disabled people are more likely to be either unemployed or
working part-time and so decisions affecting the unemployed will
have a greater impact on disabled people. State how the protected
group will be affected e.g. accessibility of a service? Impact on
standard of living/education/leisure time etc.
A project to improve the
accessibility of the website was completed in September 2020 and
accessibility standards are adhered to in all correspondence and
online messaging.
f)
Provide details of
any mitigation. What will
you be able to do to mitigate any disproportionate
impact?
The Keep will continue to be open to the public five days per week,
including Saturday mornings and additional support is available
for disabled customers, including an accessible building and
dedicated car parking spaces.
In addition, customers can access
The
Keep website. The accessibility of
the website was improved in September 2020. Content is available in
a format that users can recognise and use with the senses that are
available to them and is compatible with technologies to assist
accessibility such as screen readers to increase font
size.
Disabled access to the building
and the range of support available is advertised on The Keep
website to help customers to plan their visit in
advance.
The website enables customers to
plan their visit to The Keep in advance as well as access some
services without the need to visit The Keep building.
Customers
can browse the catalogue,
find out general information about the collections and services,
view the events programme and book and pay for tickets for
events.
Customers can
register online rather than coming into the centre. This allows
them to order documents they source on the catalogue (which they
can then view at The Keep in hard copy), create wish-lists and save
their searches for use another time.
Support is available
if customers need help using the website. “Welcome
Wednesday” sessions are run once a month which are supported
by volunteers and help new users get to know the set up and
collections
and these
will re-start when Covid-related restrictions permit.
How-to notes
are available on the website, and in paper form
at The Keep. These will be improved to make them more user-friendly
and in plain English. Volunteer computer buddies will be recruited
to support customers with low IT levels when Covid-related
restrictions permit.
g)
How will any
mitigation measures be monitored? How will
the effectiveness of mitigation be monitored?
Staff will continue to monitor
feedback regarding The Keep building and website and make
adjustments where appropriate.
4.3
Ethnicity: Testing of
disproportionate, negative, neutral or positive
impact. Race categories
are: Colour. E.g. being
black or white, Nationality e.g. being a British, Australian or
Swiss citizen, Ethnic or national origins e.g. being from a Roma
background or of Chinese Heritage
a)
How is this
protected characteristic reflected in the County
/District/Borough?
|
Protected
characteristic
|
East
Sussex
|
Eastbourne
|
Hastings
|
Lewes
|
Rother
|
Wealden
|
Brighton
& Hove
|
|
|
|
|
|
Race
|
White
British (%) – 2011
|
91.7
|
87.4
|
89.3
|
92.5
|
94.1
|
93.8
|
80.5
|
|
|
Black
and Minority Ethnic group (BME) (%) – 2011
|
8.3
|
12.6
|
10.7
|
7.5
|
5.9
|
6.2
|
19.5
|
|
Source: Census,
2011. Aggregated data
b)
How is this
protected characteristic reflected in the population of those
impacted by the proposal, project or service?
|
|
Number
of respondents
|
Percentage
|
|
White
British
|
222
|
80.14%
|
|
White
Irish
|
6
|
2.17%
|
|
White
Gypsy/Roma
|
0
|
0.0
|
|
White
Irish Traveller
|
0
|
0.0
|
|
White
other
|
9
|
3.25%
|
|
Mixed
white and Black Caribbean
|
0
|
0.0
|
|
Mixed
white and Black African
|
0
|
0.0
|
|
Mixed
white and Asian
|
0
|
0.0
|
|
Mixed
other
|
1
|
0.36%
|
|
Asian
or Asian British Indian
|
0
|
0.0
|
|
Asian
or Asian British Pakistani
|
0
|
0.0
|
|
Asian
or Asian British Bangladeshi
|
0
|
0.0
|
|
Asian
or Asian British other
|
0
|
0.0
|
|
Black
or Black British Caribbean
|
0
|
0.0
|
|
Black
or Black British African
|
1
|
0.36%
|
|
Black
or Black British other
|
0
|
0.0
|
|
Arab
|
0
|
0.0
|
|
Chinese
|
0
|
0.0
|
|
Prefer
not to say
|
20
|
7.22%
|
|
Other
ethnic group
|
4
|
1.44%
|
|
No
answer
|
14
|
5.05%
|
|
Total
|
277
|
100%
|
Respondents to
the opening hours consultation from 14 September to 25 October
2020
c)
Will people with the protected characteristic be
more affected by the proposal, project or service than those in the
general population who do not share that protected
characteristic? You will
need to refer to evidence gathered through monitoring and
consultation in conjunction with the population statistics in a).
Do you have any data available to show who will be affected by this
proposal, policy or strategy? Or is this unknown due to there being
no data available?
Over 80% of respondents to the
customer survey identified as White British and therefore have the
potential to be more affected by the reduction in opening hours
than those of other ethnicities. The greater impact on the White
British group is considered to be a reflection of the general
population of users of The Keep rather than any indication of
disproportionate impact related to ethnicity.
d)
What is the
proposal, project or service’s impact on those who are from
different ethnic backgrounds? Whilst
there may be positive and neutral factors of the proposal, policy
or strategy, which should be set out here do not try to conceal
negative impacts by only highlighting the positive
impacts
At this stage, there is not
considered to be an impact for users of The Keep of the proposed
changes to opening hours based on ethnicity.
e)
What actions are
to/ or will be taken to avoid any negative impact or to better
advance equality? Focus on
evidence of disproportionate impact i.e. where a decision affects a
protected group more than the general population. For example BME
groups are more likely to be unemployed and so decisions affecting
the unemployed will have a greater impact on BME people. State how
the protected group will be affected e.g. accessibility of a
service? Impact on standard of living/education/leisure time
etc?
No specific actions are proposed,
other than the general mitigations to reduce negative
impact.
f)
Provide details of
any mitigation. What will
you be able to do to mitigate any disproportionate
impact?
The general approach to avoid or
reduce negative impact is to continue to open five days per
week.
In addition, The Keep
website enables customers to plan their
visit to The Keep in advance as well as access some services
without the need to visit The Keep building. The website
is available 24 hours
per day from anywhere with an internet connection. Customers can browse the catalogue,
find out general information about the collections and services,
view the events programme and book and pay for tickets for
events.
Customers can
register as a Reader (get an account/become a member) online rather
than coming into the centre. This allows them to order documents
they source on the catalogue (which they can then view at The Keep
in hard copy), create wish-lists and save their searches for use
another time.
Support is available
if customers need help using the website. “Welcome
Wednesday” sessions are run once a month which are supported
by volunteers and help new users get to know the set up and
collections
and these
will re-start when Covid-related restrictions permit.
How-to notes
are available on the website, and in paper form
at The Keep. These will be improved to make them more user-friendly
and in plain English. Volunteer computer buddies will be recruited
to support customers with low IT levels when Covid-related
restrictions permit.
g)
How will any
mitigation measures be monitored? How will
the effectiveness of mitigation be monitored?
No
specific actions are proposed however we will continue to monitor
customer feedback to ensure that the changes do not impact
customers based on ethnicity.
4.4
Gender/Transgender: Testing of disproportionate,
negative, neutral or
positive impact Consider
men, women, transgender individuals.
a)
How is this
protected characteristic target group reflected in the
County/District/Borough?
|
Protected
characteristic
|
East
Sussex
|
Eastbourne
|
Hastings
|
Lewes
|
Rother
|
Wealden
|
Brighton
& Hove
|
|
|
|
|
|
Sex
|
Male
(%) - 2018
|
48.5
|
48.5
|
48.9
|
48.6
|
48.2
|
48.2
|
50.2
|
|
|
Female
(%) - 2018
|
51.5
|
51.5
|
51.1
|
51.4
|
51.8
|
51.8
|
49.8
|
|
Source: ESIF,
2018. N.B.: Gender reassignment data is not
available.
b)
How is this
protected characteristic reflected in the population of those
impacted by the proposal, project or service?
|
Gender
|
Number
of respondents
|
Percentage
|
|
Male
|
101
|
36.46%
|
|
Female
|
159
|
57.40%
|
|
Prefer
not to say
|
7
|
2.53%
|
|
No
answer
|
10
|
3.61%
|
|
Total
|
277
|
100%
|
Respondents
to the opening hours consultation from 14 September to 25 October
2020
c)
Will people with the protected characteristic be
more affected by the proposal, project or service than those in the
general population who do not share that protected
characteristic? You will
need to refer to evidence gathered through monitoring and
consultation in conjunction with the population statistics in a).
Do you have any data available to show who will be affected by this
proposal, policy or strategy? Or is this unknown due to there being
no data available?
The majority (57.4%) of
respondents to the customer survey were female and therefore have
the potential to be more impacted by the proposed changes than male
visitors to The Keep. However at this stage there is not considered
to be an impact based on gender.
d)
What is the
proposal, project or service’s impact on different
genders? Whilst
there may be positive and neutral factors of the proposal, policy
or strategy, which should be set out here do not try to conceal
negative impacts by only highlighting the positive
impacts
At this stage, there is not
considered to be an impact for users of The Keep of the proposed
changes to opening hours based on gender as the changes would
affect all current and potential users regardless of
gender.
e)
What actions are
to/ or will be taken to avoid any negative impact or to better
advance equality? Focus on
evidence of disproportionate impact i.e. where a decision affects a
protected group more than the general population. For example women
are more likely to be carers and so decisions affecting carers will
have a greater impact on women. State how the protected group will
be affected e.g. accessibility of a service? Impact on standard of
living/education/leisure time etc?
No specific actions are proposed,
other than the general mitigations to reduce negative
impact.
f)
Provide details of
any mitigation. What will
you be able to do to mitigate any disproportionate
impact?
The general approach to avoid or
reduce negative impact is to continue to open five days per
week.
In addition, The Keep
website enables customers to plan their
visit to The Keep in advance as well as access some services
without the need to visit The Keep building. The website
is available 24hrs per
day from anywhere with an internet connection. Customers can browse the catalogue,
find out general information about the collections and services,
view the events programme and book and pay for tickets for
events.
Customers can
register as a Reader (get an account/become a member) online rather
than coming into the centre. This allows them to order documents
they source on the catalogue (which they can then view at The Keep
in hard copy), create wish-lists and save their searches for use
another time.
Support is available
if customers need help using the website. “Welcome
Wednesday” sessions are run once a month which are supported
by volunteers and help new users get to know the set up and
collections
and these
will re-start when Covid-related restrictions permit.
How-to notes
are available on the website, and in paper form
at The Keep. These will be improved to make them more user-friendly
and in plain English. Volunteer computer buddies will be recruited
to support customers with low IT levels.
g)
How will any
mitigation measures be monitored? How will
the effectiveness of mitigation be monitored?
No specific actions are proposed
however we will continue to monitor customer feedback to ensure
that the changes do not disproportionately impact customers based
on gender.
4.5
Marital Status/Civil Partnership: Testing of disproportionate,
negative, neutral or positive impact. Marriage is defined as a 'union between a man and a
woman'. Same-sex couples can have their relationships legally
recognised as 'civil partnerships'. Civil partners must be
treated the same as married couples on a wide range of legal
matters.
a)
How is this
protected characteristic target group reflected in the
County/District/Borough?
|
Protected
characteristic
|
East
Sussex
|
Eastbourne
|
Hastings
|
Lewes
|
Rother
|
Wealden
|
Brighton
& Hove
|
|
|
|
|
|
Marital
& Civil Partnership status
|
Single
(never married or never registered a same-sex civil partnership)
(%) - 2011
|
29.1
|
33.3
|
36.5
|
28.7
|
24.7
|
24.9
|
50.1
|
|
|
Married
(%) - 2011
|
48.4
|
42.8
|
39.2
|
49.6
|
51.3
|
55.1
|
31.8
|
|
|
In a
registered same-sex civil partnership (%) – 2011
|
0.3
|
0.4
|
0.3
|
0.5
|
0.3
|
0.2
|
1.0
|
|
|
Separated
(but still legally married or still legally in a same-sex civil
partnership) (%) – 2011
|
2.7
|
3
|
3.7
|
2.5
|
2.6
|
2.3
|
2.5
|
|
|
Divorced
or formerly in a same-sex civil partnership which is now legally
dissolved (%) – 2011
|
10.7
|
11.5
|
12.8
|
10.2
|
10.3
|
9.4
|
9.1
|
|
|
Widowed
or surviving partner from a same-sex civil partnership (%) -
2011
|
8.7
|
9.1
|
7.4
|
8.4
|
10.8
|
8.2
|
5.5
|
|
b)
How is this
protected characteristic reflected in the population of those
impacted by the proposal, project or service?
|
|
Number
of respondents
|
Percentage
|
|
Yes
|
165
|
59.57%
|
|
No
|
57
|
20.58%
|
|
Prefer
not to say
|
33
|
11.91%
|
|
No
answer
|
22
|
7.94%
|
|
Total
|
277
|
100%
|
Respondents to
the opening hours consultation from 14 September to 25 October
2020
c)
Will people with the protected characteristic be
more affected by the proposal, project or service than those in the
general population who do not share that protected
characteristic? You will
need to refer to evidence gathered through monitoring and
consultation in conjunction with the population statistics in a).
Do you have any data available to show who will be affected by this
proposal, policy or strategy? Or is this unknown due to there being
no data available?
At this stage, there is not
considered to be an impact for users of The Keep of the proposed
changes to opening hours based on their marital status.
d)
What is the
proposal, project or service’s impact on people who are
married or same sex couples who have
celebrated a civil
partnership? Whilst
there may be positive and neutral factors of the proposal, policy
or strategy, which should be set out here do not try to conceal
negative impacts by only highlighting the positive
impacts
As above.
e)
What actions are
to/ or will be taken to avoid any negative impact or to better
advance equality? Focus on
evidence of disproportionate impact i.e. where a decision affects a
protected group more than the general population. For example
decisions about maternity and paternity leave will affect both
those who are married and those who have celebrated a civil
partnership. State how the protected group will be affected e.g.
accessibility of a service? Impact on standard of
living/education/leisure time etc.
No specific actions are proposed,
other than the general mitigations to reduce negative
impact.
f)
Provide details of
any mitigation. What will
you be able to do to mitigate any disproportionate
impact?
The general approach to avoid or
reduce negative impact is to continue to open five days per
week.
In addition, The Keep
website enables customers to plan their
visit to The Keep in advance as well as access some services
without the need to visit The Keep building. The website
is available 24hrs per
day from anywhere with an internet connection. Customers can browse the catalogue,
find out general information about the collections and services,
view the events programme and book and pay for tickets for
events.
Customers can
register as a Reader (get an account/become a member) online rather
than coming into the centre. This allows them to order documents
they source on the catalogue (which they can then view at The Keep
in hard copy), create wish-lists and save their searches for use
another time.
Support is available
if customers need help using the website. “Welcome
Wednesday” sessions are run once a month which are supported
by volunteers and help new users get to know the set up and
collections
and these
will re-start when Covid-related restrictions permit.
How-to notes
are available on the website, and in paper form
at The Keep. These will be improved to make them more user-friendly
and in plain English. Volunteer computer buddies will be recruited
to support customers with low IT levels when Covid-related
restrictions permit.
g)
How will any
mitigation measures be monitored? How will
the effectiveness of mitigation be monitored?
No specific actions are proposed
however we will continue to monitor customer feedback to ensure
that the changes do not disproportionately impact customers based
on marital status.
4.6
Pregnancy and maternity:Testing of disproportionate,
negative, neutral or positive impact.
Women who
are pregnant. Women within the first 26 weeks beginning with the
day on which she gives birth (including stillborn)
a)
How is this
protected characteristic target group reflected in the
County/District/Borough?
|
Protected
characteristic
|
East
Sussex
|
Eastbourne
|
Hastings
|
Lewes
|
Rother
|
Wealden
|
Brighton
& Hove
|
|
|
|
|
|
Pregnancy
& maternity
|
Live
births (2018)
|
4,941
|
981
|
1,069
|
877
|
700
|
1,314
|
2,521
|
|
|
Births
per 1,000 females (2018)
|
8.9
|
9.5
|
11.5
|
8.5
|
7.3
|
8.2
|
8.7
|
|
|
Live
births by mother’s country of birth - UK (%)
(2018)
|
85.3
|
75.1
|
84.8
|
85.6
|
91.0
|
90.0
|
71.1
|
|
|
Teenage
pregnancy, rate per 1,000 females (2017)
|
15.9
|
13.4
|
30
|
16.4
|
18.1
|
7.5
|
19.3
|
|
b)
How is this
protected characteristic reflected in the population of those
impacted by the proposal, project or service?
|
|
Number
of respondents
|
Percentage
|
|
Yes
|
1
|
0.36%
|
|
No
|
190
|
68.59%
|
|
Prefer
not to say
|
25
|
9.03%
|
|
No
answer
|
61
|
22.02%
|
|
|
277
|
100%
|
Respondents to
the opening hours consultation from 14 September to 25 October
2020
c)
Will people with the protected characteristic be
more affected by the proposal, project or service than those in the
general population who do not share that protected
characteristic?You will
need to refer to evidence gathered through monitoring and
consultation in conjunction with the population statistics in a).
Do you have any data available to show who will be affected by this
proposal, policy or strategy? Or is this unknown due to there being
no data available?
At this stage, there is not
considered to be an impact for users of The Keep of the proposed
changes to opening hours based on this protected
characteristic.
d)
What is the
proposal, project or service’s impact on pregnant women and
women within the first 26 weeks of maternity leave?
Whilst
there may be positive and neutral factors of the proposal, policy
or strategy, which should be set out here do not try to conceal
negative impacts by only highlighting the positive
impacts
As
above.
e)
What actions are
to/ or will be taken to avoid any negative impact or to better
advance equality? Focus on
evidence of disproportionate impact i.e. where a decision affects a
protected group more than the general population. For example
pregnant women need to be mindful of heavy lifting/physical
excursion so decisions affecting duties of care workers will have a
bigger impact on pregnant women than those who are not pregnant.
State how the protected group will be affected e.g. accessibility
of a service? Impact on standard of living/education/leisure time
etc.
No specific actions are proposed,
other than the general mitigations to reduce negative
impact.
f)
Provide details of
the mitigation What will
you be able to do to mitigate any disproportionate
impact?
The general approach to avoid or
reduce negative impact is to continue to open five days per
week.
In addition, The Keep
website enables customers to plan their
visit to The Keep in advance as well as access some services
without the need to visit The Keep building. The website
is available 24hrs per
day from anywhere with an internet connection. Customers can browse the catalogue,
find out general information about the collections and services,
view the events programme and book and pay for tickets for
events.
Customers can
register as a Reader (get an account/become a member) online rather
than coming into the centre. This allows them to order documents
they source on the catalogue (which they can then view at The Keep
in hard copy), create wish-lists and save their searches for use
another time.
Support is available
if customers need help using the website. “Welcome
Wednesday” sessions are run once a month which are supported
by volunteers and help new users get to know the set up and
collections
and these
will re-start when Covid-related restrictions permit.
How-to notes
are available on the website, and in paper form
at The Keep. These will be improved to make them more user-friendly
and in plain English. Volunteer computer buddies will be recruited
to support customers with low IT levels when Covid-related
restrictions permit.
g)
How will any
mitigation measures be monitored? How will
the effectiveness of mitigation be monitored?
No specific actions are proposed
however we will continue to monitor customer feedback to ensure
that the changes do not disproportionately impact pregnant women
and women within the first 26 weeks of maternity leave.
4.7
Religion, Belief: Testing of disproportionate, negative, neutral or
positive
impact. Including
Christian, Catholic, Jewish, Sikh, Hindu, Rastafarian, Muslim,
Buddhist, Or similar philosophical belief Agnosticism, Atheism,
Confucianism, Humanism, Taoism
a)
How is this
protected characteristic reflected in the
County/District/Borough?
|
Protected
characteristic
|
East
Sussex
|
Eastbourne
|
Hastings
|
Lewes
|
Rother
|
Wealden
|
Brighton
& Hove
|
|
|
|
|
|
Religion
|
Christian
(%) – 2011
|
59.9
|
59.6
|
51.9
|
57
|
64.8
|
64
|
42.9
|
|
|
No
religion (%) – 2011
|
29.6
|
29.2
|
36.6
|
32.5
|
25.2
|
26.3
|
42.4
|
|
|
Religion
not stated (%) - 2011
|
8.1
|
8
|
8.3
|
8.2
|
8.2
|
7.9
|
8.8
|
|
|
Muslim
(%) – 2011
|
0.8
|
1.5
|
1.3
|
0.6
|
0.5
|
0.4
|
2.2
|
|
|
Other
religion (%) – 2011
|
0.7
|
0.6
|
0.7
|
0.6
|
0.6
|
0.8
|
0.8
|
|
|
Buddhist
(%) – 2011
|
0.4
|
0.5
|
0.5
|
0.5
|
0.3
|
0.3
|
1.0
|
|
|
Hindu
(%) – 2011
|
0.3
|
0.4
|
0.5
|
0.3
|
0.2
|
0.1
|
0.7
|
|
|
Jewish
(%) – 2011
|
0.2
|
0.2
|
0.2
|
0.3
|
0.2
|
0.2
|
1.0
|
|
|
Sikh
(%) – 2011
|
0
|
0.1
|
0
|
0
|
0
|
0
|
0.1
|
|
Source: Census
2011
b)
How is this
protected characteristic reflected in the population of those
impacted by the proposal, project or service?
|
|
Number
of respondents
|
Percentage
|
|
Christian
|
88
|
88.89%
|
|
Buddhist
|
1
|
1.01%
|
|
Hindu
|
0
|
0.0
|
|
Jewish
|
1
|
1.01%
|
|
Muslim
|
1
|
1.01%
|
|
Sikh
|
0
|
0.0
|
|
Other
|
8
|
8.08%
|
|
Total
|
99
|
100%
|
Respondents to
the opening hours consultation from 14 September to 25 October
2020
c)
Will people with the protected characteristic be
more affected by the proposal, project or service than those in the
general population who do not share that protected
characteristic? You will
need to refer to evidence gathered through monitoring and
consultation in conjunction with the population statistics in a).
Do you have any data available to show who will be affected by this
proposal, policy or strategy? Or is this unknown due to there being
no data available?
At this stage, there is not
considered to be an impact for users of The Keep of the proposed
changes to opening hours based on religion.
d)
What is the
proposal, project or service’s impact on the people with
different religions and beliefs? Whilst
there may be positive and neutral factors of the proposal, policy
or strategy, which should be set out here do not try to conceal
negative impacts by only highlighting the positive
impacts
As above.
e)
What actions are
to/ or will be taken to avoid any negative impact or to better
advance equality? Focus on
evidence of disproportionate impact i.e. where a decision affects a
protected group more than the general population. For example
certain places of worship will have worshipers who travel by car to
attend services and are therefore more likely to be affected if
there is a change to parking restrictions near places of worship.
State how the protected group will be affected e.g. accessibility
of a service? Impact on standard of living/education/leisure time
etc?
No specific actions are proposed,
other than the general mitigations to reduce negative
impact.
f)
Provide details of
any mitigation. What will
you be able to do to mitigate any disproportionate
impact?
The general approach to avoid or
reduce negative impact is to continue to open five days per
week.
In addition, The Keep
website enables customers to plan their
visit to The Keep in advance as well as access some services
without the need to visit The Keep building. The website
is available 24hrs per
day from anywhere with an internet connection. Customers can browse the catalogue,
find out general information about the collections and services,
view the events programme and book and pay for tickets for
events.
Customers can
register as a Reader (get an account/become a member) online rather
than coming into the centre. This allows them to order documents
they source on the catalogue (which they can then view at The Keep
in hard copy), create wish-lists and save their searches for use
another time.
Support is available
if customers need help using the website. “Welcome
Wednesday” sessions are run once a month which are supported
by volunteers and help new users get to know the set up and
collections
and these
will re-start when Covid-related restrictions permit.
How-to notes
are available on the website, and in paper form
at The Keep. These will be improved to make them more user-friendly
and in plain English. Volunteer computer buddies will be recruited
to support customers with low IT levels when Covid-related
restrictions permit.
g)
How will any
mitigation measures be monitored?
How will
the effectiveness of mitigation be monitored?
No specific actions are proposed
however we will continue to monitor customer feedback to ensure
that the changes do not disproportionately impact people who follow
a particular religion or hold a particular belief.
4.8
Sexual Orientation - Gay, Lesbian, Bisexual and Heterosexual:
Testing of disproportionate, negative, neutral or positive
impact. The term
gay can be used to describe a gay man and a
lesbian.
a)
How is this
protected characteristic reflected in the
County/District/Borough?
|
Sexual
Orientation
|
UK
estimate
|
|
Heterosexual
|
93.5%
|
|
Lesbian or
Gay
|
1.1%
|
|
Bisexual
|
0.4%
|
|
Other
|
0.3%
|
|
Did not
answer
|
4.7%
|
|
Total
|
100%
|
Source: ONS,
Self-Perceived Identity Overview, 2012
b)
How is this
protected characteristic reflected in the population of those
impacted by the proposal, project or service?
|
|
Number
of respondents
|
Percentage
|
|
Bi/Bisexual
|
5
|
1.81%
|
|
Heterosexual
|
192
|
70.40%
|
|
Gay
woman / lesbian
|
5
|
1.81%
|
|
Gay
man
|
9
|
3.25%
|
|
Other
|
2
|
0.72%
|
|
Prefer
not to say
|
41
|
14.8%
|
|
No
answer
|
20
|
7.22%
|
|
Total
|
277
|
100%
|
Respondents to
the opening hours consultation from 14 September to 25 October
2020
c)
Will people with the protected characteristic be
more affected by the proposal, project or service than those in the
general population who do not share that protected
characteristic? You will
need to refer to evidence gathered through monitoring and
consultation in conjunction with the population statistics in a).
Do you have any data available to show who will be affected by this
proposal, policy or strategy? Or is this unknown due to there being
no data available?
At this stage, there is not
considered to be an impact for users of The Keep of the proposed
changes to opening hours based on sexual orientation.
d)
What is the
proposal, project or service’s impact on people with
differing sexual orientation? Whilst
there may be positive and neutral factors of the proposal, policy
or strategy, which should be set out here do not try to conceal
negative impacts by only highlighting the positive
impacts
As above.
e)
What actions are
to/ or will be taken to avoid any negative impact or to better
advance equality? Focus on
evidence of disproportionate impact i.e. where a decision affects a
protected group more than the general population. For example gay
men are more likely to be smokers and so decisions affecting
smoking cessation services will have a greater impact on gay men.
State how the protected group will be affected e.g. accessibility
of a service? Impact on standard of living/education/leisure time
etc.
No specific actions are proposed,
other than the general mitigations to reduce negative
impact.
f)
Provide details of
the mitigation What will
you be able to do to mitigate any disproportionate
impact?
The general approach to avoid or
reduce negative impact is to continue to open five days per
week.
In addition, The Keep
website enables customers to plan their
visit to The Keep in advance as well as access some services
without the need to visit The Keep building. The website
is available 24hrs per
day from anywhere with an internet connection. Customers can browse the catalogue,
find out general information about the collections and services,
view the events programme and book and pay for tickets for
events.
Customers can
register as a Reader (get an account/become a member) online rather
than coming into the centre. This allows them to order documents
they source on the catalogue (which they can then view at The Keep
in hard copy), create wish-lists and save their searches for use
another time.
Support is available
if customers need help using the website. “Welcome
Wednesday” sessions are run once a month which are supported
by volunteers and help new users get to know the set up and
collections
and these
will re-start when Covid-related restrictions permit.
How-to notes
are available on the website, and in paper form
at The Keep. These will be improved to make them more user-friendly
and in plain English. Volunteer computer buddies will be recruited
to support customers with low IT levels.
g)
How will any
mitigation measures be monitored? How will
the effectiveness of mitigation be monitored?
No specific actions are proposed
however we will continue to monitor customer feedback to ensure
that the changes do not disproportionately impact people with this
protected characteristic.
4.9
Other: Additional groups/factors that may experience impacts -
testing of disproportionate, negative, neutral or positive
impact. These
other groups include factors such as carers, literacy, health,
rurality, poverty, - including part time workers etc.
4.9.1 Additional
Factor 1: Carers
a)
How are these
groups/factors reflected in the County/District/
Borough?
Provision of
unpaid care, East Sussex and District (Percentage)
|
|
East
Sussex
|
Eastbourne
|
Hastings
|
Lewes
|
Rother
|
Wealden
|
Brighton
and Hove
|
|
People
provide no unpaid care
|
88.7
|
89.4
|
89.5
|
88.2
|
87.6
|
88.8
|
|
|
People
provide unpaid care
|
11.3
|
10.6
|
10.5
|
11.8
|
12.4
|
11.2
|
|
|
Provides
1 to 19 hours unpaid care a week
|
7.5
|
6.7
|
6.3
|
8.2
|
8
|
8
|
|
|
Provides
20 to 49 hours unpaid care a week
|
1.3
|
1.3
|
1.5
|
1.2
|
1.4
|
1.2
|
|
|
Provides
50 or more hours unpaid care a week
|
2.5
|
2.6
|
2.7
|
2.4
|
3
|
2.1
|
|
Source: 2011,
Census, East Sussex in Figures.
b)
How is this
group/factor reflected in the population of those impacted by the
proposal, project or service?
|
|
Number
of respondents
|
Percentage
|
|
Yes
|
28
|
10.11%
|
|
No
|
206
|
74.37%
|
|
Prefer
not to say
|
11
|
3.97%
|
|
Not
answered
|
32
|
11.55%
|
|
Total
|
277
|
100%
|
Respondents to
the opening hours consultation from 14 September to 25 October
2020
c)
Will people within these groups or affected by
these factors be more affected by the proposal, project or service
than those in the general population who are not in those groups or
affected by these factors?
You will
need to refer to evidence gathered through monitoring and
consultation in conjunction with the population statistics in a).
Do you have any data available to show who will be affected by this
proposal, policy or strategy? Or is this unknown due to there being
no data available?
Due to caring responsibilities,
carers may have less flexibility about the time and day that they
can visit The Keep compared to other members of the
public.
d)
What is the
proposal, project or service’s impact on the factor or
identified group?
The proposed changes have been
developed to minimise the impact for current visitors to The Keep.
This has been done by opening only 30 minutes later on three days
and closing only one hour earlier, with the exception of Thursday
and Saturday afternoons when the building would be closed from 1pm.
Please refer to the table of current and proposed opening hours in
2.1 b).
As a result of the way the
proposed reduction in hours is spread across five days, it is not
anticipated that the proposed reduction would disproportionately
negatively impact customers with caring
responsibilities.
However, if people with caring
responsibilities were unable to visit within the reduced hours they
would be more reliant on the website or be able to visit The Keep
less frequently.
e)
What actions are
to/ or will be taken to avoid any negative impact or to better
advance equality? Focus on
evidence of disproportionate impact i.e. where a decision affects a
factor or protected group more than the general population. For
example those who live in very rural locations are more likely to
be affected by support services being centralised. State how the
protected group will be affected e.g. accessibility of a service?
Impact on standard of living/education/leisure time
etc?
A project to improve the
accessibility of the website was completed in September 2020 and
accessibility standards are adhered to in all correspondence and
online messaging.
f)
Provide details of
the mitigation. What will
you be able to do to mitigate any disproportionate
impact?
The general approach to avoid or
reduce negative impact is to continue to open five days per
week.
In addition, The Keep
website enables customers to plan their
visit to The Keep in advance as well as access some services
without the need to visit The Keep building. The website
is available 24hrs per
day from anywhere with an internet connection. Customers can browse the catalogue,
find out general information about the collections and services,
view the events programme and book and pay for tickets for
events.
Customers can
register as a Reader (get an account/become a member) online rather
than coming into the centre. This allows them to order documents
they source on the catalogue (which they can then view at The Keep
in hard copy), create wish-lists and save their searches for use
another time.
Support is available
if customers need help using the website. “Welcome
Wednesday” sessions are run once a month which are supported
by volunteers and help new users get to know the set up and
collections
and these
will re-start when Covid-related restrictions permit.
How-to notes
are available on the website, and in paper form
at The Keep. These will be improved to make them more user-friendly
and in plain English. Volunteer computer buddies will be recruited
to support customers with low IT levels when Covid-related
restrictions permit.
g)
How will any
mitigation measures be monitored? How will
the effectiveness of mitigation be monitored?
No specific actions are proposed
however we will continue to monitor customer feedback to ensure
that the changes do not disproportionately impact people with this
protected characteristic.
4.10 Human
rights - Human rights place all public authorities – under an
obligation to treat you with fairness, equality, dignity, respect and
autonomy. Please look at the table below to
consider if your proposal, project or service may potentially
interfere with a human right. At this
stage take a common sense view. Any potential interference with a
human right out to be flagged by your impact assessment as a
possible legal non-compliance risk and bought to the attention of
your Performance AD.
|
Articles
|
|
|
A2
|
Right to life (e.g. pain relief,
suicide prevention)
|
|
A3
|
Prohibition of torture, inhuman or
degrading treatment (service users unable to consent, dignity of
living circumstances)
|
|
A4
|
Prohibition of slavery and forced
labour (e.g. safeguarding vulnerable adults)
|
|
A5
|
Right to liberty and security
(financial abuse)
|
|
A6 &7
|
Rights to a fair trial; and no
punishment without law (e.g. staff tribunals)
|
|
A8
|
Right to respect for private and
family life, home and correspondence (e.g. confidentiality, access
to family)
|
|
A9
|
Freedom of thought, conscience and
religion (e.g. sacred space, culturally appropriate
approaches)
|
|
A10
|
Freedom of expression
(whistle-blowing policies)
|
|
A11
|
Freedom of assembly and
association (e.g. recognition of trade unions)
|
|
A12
|
Right to marry and found a family
(e.g. fertility, pregnancy)
|
|
Protocols
|
|
|
P1.A1
|
Protection of property (service
users property/belongings)
|
|
P1.A2
|
Right to education (e.g. access to
learning, accessible information)
|
|
P1.A3
|
Right to free elections (Elected
Members)
|
Part
5
–
Conclusions and recommendations for
decision makers
5.1
Summarise how this proposal/policy/strategy will show due regard
for the three aims of the general duty across all the protected
characteristics and ESCC additional groups. Having
identified the specific impacts of the proposal in Part 4, this is
an opportunity to show that due regard has been had to the three
aims (i.e. to eliminate unlawful discrimination, harassment and
victimisation, to advance equality of opportunity between people
from different groups, and to foster good relations between people
from different groups), by linking together the identified impacts
and the mitigation measures that have been identified as
necessary.Having
due regard means consciously thinking about the three aims of the
general duty as part of the decision making, this means that
consideration of equality issues must influence decisions reached
by public bodies in how we act as employers and as service
providers
- Eliminate unlawful discrimination,
harassment and victimisation and other conduct prohibited by the
Equality Act 2010;
- Advance equality of opportunity
between people from different groups
- Foster good relations between
people from different groups
The proposed reduction to The Keep
opening hours has been developed to avoid disproportionate impact
on current users while achieving the required financial saving in
order to ensure the medium-term sustainability of The
Keep.
Appropriate mitigations have been
put in place to avoid unlawful discrimination and advance equality
of opportunity. The efficacy of these mitigations will continue to
be monitored.
The Keep contributes to the three
aims of the general duty by seeking to offer equal access to
everyone who wishes to view the archives in our
collections.
5.2
Impact assessment outcome Based on the analysis of the
impact in part four mark below ('X') with a summary of your
recommendation. Having
considered the potential or actual effect of your policy/strategy
on equality, you should be in a position to make an informed
judgement about what should be done with the
policy/strategy.
|
X
|
Outcome of impact
assessment
|
Please explain your answer
fully.
|
|
|
A No major change
– Your analysis
demonstrates that the policy/strategy is robust, and the evidence
shows no potential for discrimination and that you have taken all
appropriate opportunities to advance equality and foster good
relations between groups.
|
This is a final EqIA following
assessment of the data collected during the public consultation
regarding the proposed change to opening hours.
Based on our analysis of public
consultation data from 14 September to 25 October 2020, the
partnership is satisfied that the adoption of revised opening hours
will not unlawfully discriminate against The Keep’s current
and potential users and that we have taken reasonable steps to
ensure the needs and views of protected groups have been considered
among existing users of The Keep.
|
|
|
B Adjust the
policy/strategy – This involves taking steps
to remove barriers or to better advance equality. It can mean
introducing measures to mitigate the potential effect.
|
|
X
|
C Continue the policy/strategy
- This
means adopting your proposals, despite any adverse effect or missed
opportunities to advance equality, provided you have satisfied
yourself that it does not unlawfully discriminate
|
|
|
D Stop and remove the
policy/strategy – If there are adverse
effects that are not justified and cannot be mitigated, you will
want to consider stopping the policy/strategy altogether. If a
policy/strategy shows unlawful discrimination it must be
removed or changed.
|
Customer complaints arising from
the proposed changes to opening hours will be monitored and kept
under review by the Keep Management Team at three-monthly intervals
for a period of 12 months.
5.4
When will the amended proposal, proposal, project or service be
reviewed? Include
dates for completion and Manager(s) responsible
If approved, the proposed changes
would be implemented in April 2021 and would be reviewed 12 months
after implementation in April 2022.
The
pT
|
Date completed:
|
1/12/2020
|
Signed by
(person completing)
|
Jack Pierce
|
|
|
Role of person
completing
|
Principal Customer Services
Officer
|
|
Date:
|
4/12/20
|
Signed by
(Manager)
|
Lucy Corrie
|
