The Equality Act 2010 (the Act) replaces the previous anti-discrimination laws with a single Act

2. Review of information, equality analysis and potential actions

Consider the actual or potential impact of your project (service, or policy) against each of the equality characteristics.

Protected characteristics groups under the Equality Act 2010	What do you know? Summary of data about your service-users and/or staff	What do people tell you? Summary of service-user and/or staff feedback	What does this mean? Impacts identified from data and feedback (actual and potential)	What can you do? All potential actions to: · advance equality of opportunity, · eliminate discrimination, and · foster good relations
Age	Census data: The proportion of the population of East Sussex aged 65 and over now stands at 26.1%, up from 22.7% in 2011 and compared to 18% across England. The greatest growth occurred in the 70-74 age category, which increased by 46.6% compared to a national average of 36.8%. Service data: Of 57 people who left the service between 1^st April 2023 and 3^rd October 2024, or are still attending, 43.9% were adults aged 85+. 40.4% were adults aged 75-84, 10.5% were adults aged 65-74 and 5.3% were adults aged 18-64. National data: According to Age UK, three out of ten people aged 65 to 74 and two-thirds of those aged 75 and over are not online. There is also a link to social disadvantage. For example, while only 15 per cent of people aged 65 to 74 in socio-economic group AB do not use the internet, this rises to 45 per cent in group DE. According to the Office of National Statistics, 55% of those who are classed as non-internet users are adults aged over 75, and 24% are aged 65 to 74. According to the Centre for Ageing Better, our older population is more diverse than ever before and we are likely to see inequality grow among older people as disadvantage accumulates across the life course. Women, disabled people, carers, self-employed people, and people from some ethnic minority backgrounds are more likely to be living in poverty. The poorest people live shorter lives and live many more years in bad health. According to the DWP, almost one in five pensioners in the UK were living in relative poverty in 2023 (19% before housing costs and 16% after housing costs) and pensioners in material deprivation increased to 8%, its highest level since 2016.	The 2024 consultation on the proposed cuts to services: · Organisations were concerned that if the services close, there wouldn’t be a suitable alternative and people would become increasingly isolated which could push people into decline or crisis and lead to the use of more expensive services. · People said that there had already been a reduction in day services in the area and another cut would increase isolation. Older people told us: “Being elderly, I am worried about any loss of places which offer the possibility for elderly people who maybe live alone and/or are struggling with reduced physical and/or mental abilities.” People said the proposal would be detrimental to older people in particular. People reported that routine changes are disruptive for people who use care and support services. People said that the proposal would make the commute to services more complex. People thought that more adults would have to go into care.	The proposed changes will have a negative impact on older people. Most people accessing the service are older people, with a large proportion aged 85+. For some, this service could be their primary source of social interaction. The proposals would mean a loss of local service and friendship networks and social interaction could be negatively impacted as a result. It is likely that this would be difficult and unsettling for the older people affected. Older people living in poverty may have less access to alternative services due to the potential distance and cost of travel to get there. Older people are also more likely to be digitally excluded. It is important that any information about service changes and alternative provision is accessible and provided in a range of formats.	We have a statutory responsibility under the Care Act to meet eligible care and support needs. Should the proposals go ahead, we would ensure the needs of each individual are assessed to determine their current care needs. If the proposal went ahead, Carers Assessments or reviews will be offered to all carers affected. If the proposals go ahead, we will consider all alternative options available to meet any care needs identified. If day services continue to be provided at Milton Grange this would include Council provided day services in Eastbourne. Sourcing alternative provision will include planning for transport required. If the proposals go ahead, we will work with alternative day service providers to ensure they are appraised of the individual’s care needs and facilitate a smooth transition between services. If proposals go ahead we will ensure information is provided to people about the range of alternative resources and services in the appropriate formats for them
Disability	Census 2021 data: In the 2021 census, 20.3% of East Sussex residents were living with a long-term physical or mental health condition or impairment that affected their ability to carry out day-to-day activities (compared to 18% for England & Wales). 34.8% of households in East Sussex had at least one member identifying as disabled under the Equality Act in 2021. Service data: Of 57 people who left the service between 1st April 2023 and 3rd October 2024, or are still attending, the Primary Support Reason was as follows: 50.9% physical support 31.6% support with memory and cognition. 14% was social support (including substance misuse support) 3.5% was mental health support Service data on health conditions is as follows: 56.1% had a mental health condition (including dementia) 26.3% had a long-term physical condition 14% had a long-term neurological condition 1.8% had sensory impairment. 3.5% did not have any relevant long term health conditions and data was not recorded for 8.8% of adults. Local data: According to a report by Sussex Community Foundation, disabled people are more likely to live in areas of Sussex that are ranked as highly deprived. 27% of all people in Sussex living in the most deprived 10% of areas in the country had a disability, compared with 14% of those living in the least deprived areas.	In the 2024 consultation on the proposed savings, it was reported that: · Mental health and well-being will be affected for the adults using the service and their carers and families. · The Phoenix Centre provides vital services for many people, particularly vulnerable members of our community. “My [family member] has Alzheimer’s and spends [one day a week] there, socializing with peers and receiving excellent care and support from staff. We know [they are] safe when there, which is so important for us, and it is a tiny bit of respite for [their] family.” · The Phoenix Talking Newspaper, a free weekly service for blind or partially sighted people across Lewes district has been based at the Phoenix Centre for well over 30 years. If the studio facility is withdrawn, blind people throughout Lewes and District risk being deprived of this service. · People reported that it was a very accessible building. · People reported that many attendees do not have voice/cannot communicate. · People felt that the proposal would be detrimental to disabled people in particular. · The Phoenix Centre is a Venue for a Type 2 Diabetes group which provides valuable nutritional advice.	The proposed changes will have a negative impact on disabled people. Most adults accessing the service have physical, neurological or mental health conditions including dementia. Only 3.5% of these adults did not have a long-term health condition. Loss of day care services can increase isolation and loneliness and can have a knock-on effect on carers and families, for whom respite care is often seen as a lifeline. This could impact negatively on mental health and should be considered in the context of the broader proposal to change services, including the proposal to change the way that mental health community outreach services are provided. Accessing alternative services is likely to mean longer travel times which may be difficult for some people. It is also important that any information about service changes and alternative provision is accessible to people with sensory impairment and provided in a range of formats.	The above mitigations will apply for all protected characteristics. If day services at the Phoenix Centre were to cease, the Council’s Property Services Team and ASCH would seek continued use for other services for the building where possible or seek alternative venues.
Gender reassignment	Census data: 1640 residents declared their gender identity was different to that assigned at birth which is 0.4% of the population. Service data: All adults discharged from the service between 1^st April 2023 and 3^rd October 2024, or still open, identified as male or female. There is no specific data on adults who identify as trans. Local data: The 2021 East Sussex Lesbian Gay Bisexual Trans Queer +[1] Comprehensive Needs Assessment estimates that there may be 5,572 Trans and Gender Diverse people (1% of the population) living in East Sussex.	We did not receive any feedback from this protected characteristic.	It is not possible to determine whether any adults are trans as there is no specific data on this.	The above mitigations will apply for all protected characteristics.
Pregnancy and maternity	No one affected by this protected characteristic uses this service.	N/A	N/A	N/A
Race (ethnicity) Including migrants, refugees and asylum seekers	Census data: 88.3% of usual residents of East Sussex said that they belonged to the White: English, Welsh, Scottish, Northern Irish or British ethnic group. Ethnic minority groups including white minority groups (Irish, Gypsy or Irish Traveller, Roma, Other White) make up 11.7% of usual residents in East Sussex. This compares to 18.8% in England. Service data: Of 57 people who left the service between 1st April 2023 and 3rd October 2024, or are still attending, 86% were White British, 7% were White – any other background and 1.8% were mixed. Ethnicity was not yet obtained for 5.3% of adults using the service. Local data: According to Sussex Community Foundation, people from Non-White ethnic groups are also disproportionately likely to reside in more deprived areas of Sussex, with 14.4% living in the most deprived 10% of areas, compared with 6.6% of people in the least deprived 10% of areas in England.	We did not receive feedback from this protected characteristic.	People from ethnic minorities are underrepresented in the service. There is no evidence to indicate that people from ethnic minorities will be disproportionately impacted.	The above mitigations, under the Age section, will apply for all protected characteristics.
Religion or belief	Census data: In 2021, 45.9% of usual residents of East Sussex identified as Christian. The second most common religion in East Sussex after Christianity is Islam at 1.1%. Service data: Of 57 people who left the service between 1st April 2023 and 3rd October 2024, or are still attending, 61.4% were Christian, 17.5% had no religion, 1and 1.8% were Buddhist. 19.3% of adults did not state their religion.	We did not receive feedback from this protected characteristic.	We do not know the impact of the proposals on this protected characteristic.	The above mitigations, under the Age section, will apply for all protected characteristics
Sex	Census data: Of the population of East Sussex, 299,064 (52%) are female and 270,788 (48%) are male. Service data: Of 57 people who left the service between 1st April 2023 and 3rd October 2024, or are still attending, 70.2% were female, and 29.8% were male.	The 2024 consultation on the proposals heard: · Ceasing day services at the Phoenix Centre would be detrimental to women as it provides a lifeline for carers, very often women.	There are significantly more women using the service compared to the county’s population. While both men and women will be impacted by the proposed changes, there is a disproportionate impact on older women. More women may also be affected in their caring role.	The above mitigations, under the Age section, will apply for all protected characteristics As above, Carers Assessments or reviews will be offered to all carers affected.
Sexual orientation	Census data: According to the 2021 Census 3.3% of East Sussex residents declared themselves as LGB+. Service data: Of 57 people who left the service between 1st April 2023 and 3rd October 2024, or are still attending, 70.2% were heterosexual, 3.5% were gay/lesbian, 1.8% were unsure and 1.8% preferred not to say. sexual orientation was not recorded for 22.8% of adults. Local data: The 2021 East Sussex LGBTQI+ Comprehensive Needs Assessment estimates that there may be between 17,273 and 39,004 LGB+ people living in East Sussex (between 3.1% and 7% of the population) In adults, the GP patient survey found that mental health condition prevalence was significantly higher in LGB+ people (41%), compared to heterosexual people (11%), especially in bisexual people (56%). National data: The University of Kent Circle Project highlights that older LGBTQ+ people have lived through discriminatory policies and laws that have severely impacted their confidence in public services and led to trauma, stress, and internalised stigma, which may have significant health implications. Because of this, there is an increased need for explicit LGBTQ+ inclusive services to signal people are safe to be themselves. LGBTQ+ people may also have other increased risk factors for mental and physical health issues, such as dementia and depression. These risk factors include stress, social isolation, loneliness, HIV, and addiction.	We did not receive feedback from this protected characteristic.	The available data suggests that the proportion LGB+ people using the service is broadly in line with the County’s population. However, it is not possible to accurately assess the number of LGB+ adults accessing the service as sexual orientation was not recorded for 22.8% of adults. There is no evidence to indicate that LGB+ people will be disproportionately impacted.	The above mitigations, under the Age section, will apply for all protected characteristics
Marriage and civil partnership	Census data: According to 2021 census data for East Sussex: · Single 29% · Married 46.5% · Civil Partnership 0.4% · Divorced 11% · Widowed 8% Service data: Of 57 people who left the service between 1st April 2023 and 3rd October 2024, or are still attending, marital status was not recorded for 43.9% of adults. 22.8% were married, 21.1% were widowed, 5.3% were single, 3.5% were divorced, 1.8% were civil partnered and 1.8% did not disclose their marital status.	N/A	We do not know the impact of the proposed changes on this protected characteristic.	The above mitigations, under the Age section, will apply for all protected characteristics.
Armed Forces	No one affected by this protected characteristic uses this service.	N/A	N/A	N/A
Impacts on community cohesion			We do not know the impact of the proposed changes on community cohesion.	The above mitigations, under the Age section, will apply for all protected characteristics

Additional categories

(identified locally as potentially causing / worsening inequality)

Characteristic	What do you know?	What do people tell you?	What does this mean?	What can you do?
Rurality	Census data: 74% of the population in East Sussex lives in an urban area with the remaining 26% living in a rural area. Service data: Of 57 people who left the service between 1st April 2023 and 3rd October 2024, or are still attending, 33.4% lived in a rural area.		There may be a disproportionate impact on people living in rural areas as there are proportionately more people living in rural areas attending the service than there are in the county overall (33,4% against 26%). Older people living in rural areas may have less access to alternative services based on their location and limited transport options. This would increase the risk of isolation or loneliness among this group.	The above mitigations, under the Age section, will apply for all protected characteristics. Noting that as part of an individual’s review and support, and Carer’s assessment where appropriate, any transport requirements for alternative provision would be considered.
Carers	Local data: There are over 10,000 persons claiming CA in East Sussex. (Source DWP Feb 2020) Care for the Carers estimates that there are 69,241 unpaid carers in East Sussex. It is difficult to know the actual number of carers because so many carers are hidden. According to a report by Care for the Carers on experiences of caring in East Sussex, 99% of carers feel stressed. 96% feel that their wellbeing has been affected as a result of the caring role. 94% are feeling alone or isolated. 92% report impact on their physical health. 83% are affected financially. 42% of carers want to, but can’t access respite. Key challenges faced by carers include struggle to access services; stress, burn out and severe impact on mental health - reaching services at the point of crises. Carers say that the ability to take time out from their caring role is crucial, but access to respite care remains very low. National data: Older people with caring responsibilities face an extra strain on mental health (Age UK, 2024).	The 2024 consultation on the proposed cuts to services heard that: · A lack of access to breaks/respite is already one of the most challenging aspects of caring in East Sussex, which carers consistently tell us significantly reduces their wellbeing, and increases the likelihood of carer breakdown. · Changes in service times/days of day service provision are key risks to carers being able to negotiate or maintain flexible working with their employers. Being able to maintain employment is vital to carers’ ability to maintain choices, independence and financial wellbeing. The proposals will jeopardise this. · People said that the proposed changes will be stressful for both service users and their carers, and will destabilise caring arrangements, impacting on carers’ wellbeing. · People said that mental health and well-being will be affected for the adults using the service and their carers and families. · People said that expecting carers to drive large distances to reach a day centre further from their vicinity, would add extra pressure to the carers already difficult life. · People said that carers' ability to have longer breaks would be removed.	Given the nature of older people services, the proposed changes would have a negative impact on carers. As stated in the 2018 EqIA, loss of day care services can increase financial and emotional strain on carers and families. The primary reason people attend day services is to provide carers with a break, enabling them to continue in their caring role and for some carers, enable them to continue working. If day services are discontinued, and it is not possible to find a suitable alternative, there is a risk of carer breakdown where carers will no longer be able to continue in their caring role. This may create further risk of people having to move to long term care prematurely.	If the proposal went ahead, Carers Assessments or reviews will be offered to all carers affected. As above, transport requirements for alternative services would also be considered when reviewing adults and agreeing revised support plans.
Other groups that may be differently affected (including but not only: homeless people, substance users, care leavers)	Local data: East Sussex is fifth most deprived of 26 County Councils.13% of people aged 60 plus were living in poverty in 2019 (source Joint Strategic Needs Assessment). 10.3% of households were in fuel poverty in 2019 compared to 9.3 % in England. East Sussex has over 1200 refugees from Ukraine staying in the county. Precise data on asylum seekers and refugees is not available however East Sussex currently has six adult asylum seeker hotels, with the majority in Eastbourne. East Sussex is home to an estimated 2,300 people who use opiates and/or crack. Of these, 53.3% were in treatment at some point in 2021/22 which is above the national average of 46.3% . but it does indicate a possible further 1,050 people using opiates or crack who are not accessing treatment. Service data: Of 57 people who left the service between 1st April 2023 and 3rd October 2024, or are still attending, the primary support reason for 14% of adults was social support (including substance misuse support).	N/A	Local and national data shows that disabled people and ethnic minority people are more likely to be living in poverty and nearly one in five pensioners are living in relative poverty. People living in poverty are more likely to live in poor health for a larger number of years, and have shorter life spans. Most of the people accessing day services are older people and disabled people. Those who are also living in poverty and/or from ethnic minorities are likely to be negatively impacted by the proposals.	The above mitigations, under the Age section, will apply for all protected characteristics. Noting that as part of an individual’s review and support, and Carer’s assessment where appropriate, any transport requirements for alternative provision would be considered.

Assessment of overall impacts and any further recommendations - include assessment of cumulative impacts (where a change in one service/policy/project may have an impact on another)

If the proposed closure of day services at the Phoenix Centre went ahead it would negatively impact older people, disabled people and carers, and could negatively impact mental health conditions.

Impact for people living in rural areas should also be considered – due to increased risk of isolation if alternative services are not accessible to them; however this would be mitigated by ensuring transport requirements were considered when drawing up new support packages for alternative provision.

The disproportionate/cumulative impact of cuts on disabled people, who are more likely to be living in poverty, and with poor health, should also be considered although there is insufficient evidence to quantify this.

There is a risk that the new offer of alternative services results in the potential loss of important friendship networks.

If the Phoenix Centre day services were to close, it could increase travel time and disrupt the routines of some adults and their carers, this could impact on their health and wellbeing.

Whilst the recommendation remains to close the Phoenix Centre Day Service and support people to access alternative services in the community,

as a result of the consultation process it is now recommended that adults receiving a service at the Phoenix Centre could be offered the opportunity to consider Milton Grange day service as part of the alternative options for meeting their needs. This is dependent on Cabinet agreeing a revised proposal for Milton Grange Day Services.

The potential for day services to be offered at Milton Grange is a beneficial addition to alternatives that people can consider. Milton Grange day services have been used successfully on previous occasions to provide a day service for adults receiving a day service at Phoenix Centre. For example, when the Phoenix building has been closed for several weeks for major refurbishment works.

3. List detailed data and/or community feedback that informed your EqIA

Source and type of data (e.g. research, or direct engagement (interviews), responses to questionnaires, etc.)	Date	Gaps in data	Actions to fill these gaps: who else do you need to engage with? (add these to the Action Plan below, with a timeframe)
See above for responses to the 2024 consultation on this proposal.

4. Prioritised Action Plan

NB: These actions must now be transferred to service or business plans and monitored to ensure they achieve the outcomes identified.

Impact identified and group(s) affected	Action planned	Expected outcome	Measure of success	Timeframe
Relevant across protected characteristics	Should the proposals go ahead, we would work to ensure the needs of each individual are assessed to determine their current care needs.	Best alternative support plan to meet eligible needs is agreed with adult (and carer where appropriate)	New support plan agreed	Beginning April 2025
Relevant across protected characteristics	If the proposals go ahead, we will consider all alternative options available to meet any care needs identified including travel requirements and other Council provided day services if available.	Best alternative support plan to meet eligible needs is agreed with adult (and carer where appropriate)	New support plan agreed	Beginning April 2025
Relevant across protected characteristics	If the proposals go ahead, we will aim to work with alternative day service providers to ensure they are appraised of the individual’s care needs and facilitate a smooth transition between services.	Transition to alternative services minimises disruption for adults and carers	New support plan agreed and transition managed smoothly between services	Beginning April 2025
Relevant across protected characteristics	If proposals go ahead, we will link with the Information, Guidance and Feedback team to explore the feasibility of providing information to people about the range of alternative resources and services to meet their identified care needs.	People have the information they need in formats which are accessible to them	People can make informed choices about alternative service options	Beginning April 2025
The proposals would have a negative impact on carers who would lose respite support. This would increase financial and emotional strain, and could lead to carers being unable to continue in their caring role.	If proposals go ahead, carers would be offered a carer’s assessment or a review Carer’s needs and outside commitments will also be considered when support planning for the adult	Carers can continue in their caring role Carers can continue with commitments such as work or other activities which are important to them	Carers can continue in their caring role	Beginning April 2025

Title of Project/Service/Policy	Phoenix Centre Day Service, Lewes
Team/Department	Older People’s Directly Provided Services
Directorate	Adult Social Care & Health (ASCH)
Provide a comprehensive description of your Project (Service/Policy, etc.) including its Purpose and Scope	Summary of changes to original proposal and revisions to Equalities Impact Assessment The proposal remains to cease providing day services at the Phoenix Centre, Lewes and to offer attendees alternative services to meet their needs. However, the original proposal has been amended to take account of the revised proposal to Cabinet, regarding Milton Grange Day Services in Eastbourne. If Cabinet agree to continue to provide day services at Milton Grange then this will be one of the alternative service options available for attendees at the Phoenix Centre to consider. This would provide a level of mitigation for some of the impacts, which is reflected below in this EqIA. Background and original proposal The day service at the Phoenix Centre, in Lewes, is run by East Sussex County Council. The service delivers support to older people with a range of complex physical and mental health needs. The aim of the service is to prevent social isolation and provide respite for carers to give them a break from their caring role or allow them to work. The service has 12 members of staff, who are all employed by the Council. It has space for up to 25 people a day from Monday to Friday between 10am and 4pm. Transport to and from the day service is provided, as well as a hot lunch. Some people who use the service have complex needs that require one-to-one staffing support. There are currently 29 people who attend the service with a maximum of 25 on any given day, with most people attending for one or two days a week. Attendance is highest on Wednesday and Friday. The majority of people who attend the day service live in Lewes (42%) with the remainder living in the surrounding towns such as Peacehaven, Newhaven and Uckfield. The service provides physical and cognitive stimulation through a range of activities including chair-based exercise, reminiscence, arts and crafts, interactive quizzes, puzzles and games, as well as day trips. What we are proposing We are proposing to cease providing day services at the Phoenix Centre and to support people to access alternative services in the community. People would be supported to look at alternative options by our social care staff. If the proposal went ahead all adults affected would be offered an individual review to ensure that their support package continues to meet their assessed needs. Where day services continue to be the preferred option, Adult Social Care and Health (ASCH) would work with people to source an alternative service. Carers would also be offered a carers assessment, or a review of their assessment, to determine whether support packages continue to meet their assessed needs. There are a range of day services for older people across East Sussex run by private providers and voluntary sector organisations. The map below shows the services we are currently aware of: The consultation processes on the ASCH savings proposed in September 2024 have led to some changes being made to the original proposals. It is now being proposed that day services should continue to be provided from Milton Grange on weekdays, If the revised proposal for Milton Grange Day Services is agreed then people who have been attending the Phoenix Centre would be able to consider day services at Milton Grange as well as those provided by the independent, voluntary, community and social enterprise sectors, if it is agreed to cease provision of day services at the Phoenix Centre. Why we are proposing this saving While we recognise the importance of this service, the budget pressures we face mean that we have to make difficult decisions about how we spend our money. Under the Care Act, we are required to meet people’s eligible needs, but that doesn’t necessarily mean providing the service ourselves. There are day services available from other organisations, and personal assistants (PA’s), that can support this group of people, potentially at a lower cost, so it makes sense to make use of those rather than committing the money required to run the service ourselves. As these proposals include significant changes to services, a public consultation started on 3^rd October 2024, running for 8 weeks until 28^th November 2024. The results will be presented, alongside this Equality Impact Assessment in a Cabinet paper in February 2025. This EqIA reflects that the proposal remains to close the Phoenix Centre Day Service and support people to access alternative services in the community. It takes account of the potential (depending on decisions made regarding Milton Grange Day Services) for adults currently receiving a service at the Phoenix Centre to consider Milton Grange day services as well as other alternative services in the community. The main risks of going ahead with the proposal are: · Increased transport time to access alternative services. · Changes to the days people attend. This will be dependent on capacity within alternative services. · People will experience a significant change in how they receive their service in the future. This may have an impact on their health and wellbeing. If this proposal is agreed, all adults who are affected will be offered an adult social care review to consider how best to meet their eligible needs going forward. As above, depending on decisions regarding Milton Grange Day Services the alternative service provision available may include Milton Grange in Eastbourne as well as other community services. Carers would also be offered a Carer’s Assessment or a review to mitigate any adverse impact created by the changes to day service provision for the cared for person.