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

According to the 2021 Census, the proportion of the population of East Sussex aged 65 and over now stands at 26.1%, up from 22.7% in 2011.

Proportion of Population by age range (%):

East Sussex

0-19 20-44 45-64 65+

21 25 28 26

England

23 33 26 18

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.

Of people living in the supported accommodation

(Park Lane, Field Cottage, the Ferns and the Martins), the age range is:

· 18-30 3

· 30-40 6

· 40-50 5

· 50-65 11

· 65+. 4

Of those who access the Community Support Services but live in the community rather than within one of the 4 Supported Living schemes, the age range is:

· 20-40 9

· 41-50 8

· 51-65 10

· 65+ 6

The total number of young people with a learning disability who will be turning 18 and transitioning to ASC are:

this financial year (2024-2025): 10 (4 of these are 18 already, 6 are 17 years old), (2 of the 10 are external referrals so did not transfer from CDS)
2025-2026: 14
2026-2027: 15

The majority of respondents to the consultation were aged between 45-54, 60-64, and 25-34 (9%, 7% and 6% respectively).

There is a smaller proportion of those aged 65+ compared to the population of the county and people receiving long term support overall. This is to be expected as this service targets those of working age and life expectancy is considerably lower for people with a learning disability.

No specific mitigations required for this characteristic.

Disability

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 in 2021, the same proportion as in 2011 (compares 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.

According to Ofcom research, people with a learning disability are most likely to say that their use of TVs or computers is either limited or completely prevented due to their condition. Nearly two in ten (18%) said their use of TVs or computers was limited or prevented, while around one in ten said the same for the internet, landline, smartphones, or simple mobile phones.

All adults within supported accommodation have a Learning, Development, or Intellectual Disability. One is visually impaired; one has limited mobility in the arm.

Of those who access the Community Support Services, but live in the community rather than within one of the 4 Supported Living schemes, 8 adults have autism (two of these with additional physical needs, another with an additional sensory impairment, and another with a neurological impairment), 4 with additional physical needs (one of these with a sensory impairment), 2 solely with a sensory impairment, 5 with a neurological disability (one with additional sensory and physical disabilities), two have depression and one with aspergers - 20 adults in total.

Consultation respondents felt that removing this service would affect the most vulnerable and disabled people in particular, although some respondents expressed that the service is not cost effective and that the changes would not affect them.

People said that closing CSS would destroy their support structure and stability, and affect people’s independence. It is therefore likely to lead to poorer mental and physical health for those affected.

NHS Sussex expressed a view that “no support or reduced support with activities of daily living such as food shopping, could lead to poorer general health, increase in health inequalities and increased use of health services.”

All adults accessing the services included in the proposals have a learning disability or are deemed to be vulnerable. Some people may have further complexities such as sensory impairment, physical disabilities and other health problems which may impact on them further.

Of those affected by this proposal 100% are disabled (compared to 20% of the population). A change in routine may cause people using the service anxiety, increase isolation, and have a negative impact upon their independence.

Any changes agreed may also cause adults increased emotional and/ or psychological distress.

As the adults supported by CSS live independently many access a range of other organisations and services such as DWP, housing benefit, probation etc. as they would often be supported to access these organisations. Without CSS there is a risk these appointments could be missed, generating more work for re-arranging missed appointments and possibly the support not being correctly received e.g. housing benefit not being paid.

The revised proposal for ASCH Learning Disability Directly Provided Services to offer a Community Outreach service in place of the current CSS will mitigate these impacts.

For the five adults who access services on a Saturday (when services would no longer be provide under the new proposal) we will undertake an ASCH review and support planning exercise, commissioning alternative services to meet needs as required.

Ensure information is given in an appropriate and accessible format. Staff should be available to support those who need it to process the information. Advocacy services will be offered.

Any additional support or service required due to disability will be picked up within the individual review that is proposed.

Gender reassignment

The 2021 East Sussex Lesbian Gay Bisexual Trans Queer + (LGBTQ+)[1] Comprehensive Needs Assessment estimates that there may be 5,572 Trans and Gender Diverse (TGD) people (1% of the population) living in East Sussex

2021 Census: 1640 residents declared their gender identity was different to that assigned at birth which is 0.4% of the population.

Adult data tells us that there are no adults with this protected characteristic.

We did not receive any feedback from anyone in this protected characteristic.

There are no adults with this characteristic therefore no impact identified

No specific mitigations required at this time.

Pregnancy and maternity

There are just under 5,000 births per year in East Sussex. Hastings has the highest overall birth rate as well as for women aged 15-19 years. Lewes and then Rother have the highest birth rates for women aged 35-44 years.

Data tells us that there are no adults with this protected characteristic.

We did not receive any feedback from anyone in this protected characteristic.

There are no adults with this characteristic so no impact identified.

No specific mitigations required at this time.

If there were adults with this protected characteristic, any support needs would be picked up by an ASCH Review and appropriate support would be provided

Race (ethnicity)

Including migrants, refugees, and asylum seekers

88.3% of usual residents of East Sussex said that they belonged to the White: English, Welsh, Scottish, Northern Irish or British ethnic group. Black and minority ethnic 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.

In 2021, 93.9% (512,440) of usual residents in East Sussex identified their ethnic group within the high-level "White" category, a decrease from 96.0% (505,420) in the 2011 Census, but still significantly higher than the English national average (81.0%) and also higher than the average for the Southeast region (86.6%).

4.6% were of another white background; 1.6% were Asian/ Asian British, 0.5% were Black/ Black British and1.3.% were from other ethnic backgrounds.

Those selecting a non-UK identity only accounted for 5.5% of the overall population (29,880 people), which is an increase from 4.3% of the population (23,090 people) in 2011. The most common non-UK identities are Polish, Irish, Romanian, Portuguese, and Italian.

A higher percentage of the population in East Sussex identified as Gypsy or Irish Traveller than the national average (0.2% compared to 0.1%).

Of adults living in the supported accommodation

(Park Lane, Field Cottage, the Ferns and the Martins), the ethnicity data tells us:

White – British 28

Mixed - Any Other Mixed Background 2

Of those who access the Community Support Services, but live in the community rather than within one of the 4 Supported Living schemes, the recorded ethnicity data is:

White British 32

Any Other Ethnic Group 1

We did not receive any feedback from anyone in this protected characteristic.

97% of people using these services are White British, this is higher than the proportion of White British people in the County’s overall population (88.3%). Therefore there is a slightly disproportionate impact upon this group.

Access Translation and Interpreting services if required; ensure staff are aware of the process.

Culturally appropriate services to be considered as part of the individual review of needs as required.

The data reflects referrals received so no further mitigations required.

Religion or belief

In 2021, 45.9% (250,330) of usual residents of East Sussex identified as Christian, down from 59.9% (315,650) in 2011.

The second most common religion in East Sussex after Christianity is Islam. The proportion of the population stating they were Muslim increased from 0.8% of the usual resident population (4,200) in 2011 to 1.1% (6,190) in 2021. This is low compared to both the Southeast Regional and the English national averages, with 3.3% of residents in the Southeast specified their religion as Islam, and 6.7% across the whole of England.

Details of the impact upon religion and belief on ASC:

Religion and Belief in Health and Social Care Assessments.

Data on religion is not available.

No feedback was received from anyone with this protected characteristic.

Limited data available. However where faith is important to an adult this is picked up during the assessment and recorded on the support plan. This does not apply to any adults at this time so no impact identified.

No specific mitigations required at this time.

Where an adult requests a specific need to be supported with their religion this would be picked up during an assessment and recorded on their support plan.

Sex

Of the population of East Sussex, 299,064 (52%) are female and 270,788 (48%) are male.

Of adults living in the supported accommodation

(Park Lane, Field Cottage, the Ferns, and the Martins):

· Male 17

· Female 13

Of those who access the Community Support Services, but live in the community rather than within one of the 4 Supported Living schemes:

· Male 27

· Female 6

Nearly double the number of women took part in the consultation than men (39% compared to 22%).

There are significantly more males using the Community Services compared to the County’s population. So males will be more affected than females by this proposal.

This data depends on referrals received so no mitigations specifically required for this characteristic.

Sexual orientation

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)

According to the 2021 Census 3.3% of East Sussex residents declared themselves as LGB+.

Of adults living in the supported accommodation

(Park Lane, Field Cottage, the Ferns and the Martins), two are recorded as heterosexual with the remainder of the records blank.

Of those who access the Community Support Services, but live in the community rather than within one of the 4 Supported Living schemes:

One adult is recorded as heterosexual, the remainder of the data in this field is blank.

We did not receive any feedback from anyone in this protected characteristic.

Data available on sexual orientation is limited.

If sexual orientation affects support required then this would be picked up during the assessment process and recorded on the support plan. We are not aware of any adults this applies to at this time, so no impact is anticipated upon those who share this characteristic.

Improve data collection on this protected characteristic.

Recording of sexual orientation is monitored via a dashboard sent out quarterly to heads of service.

Marriage and civil partnership

According to 2021 census data for East Sussex:

· Single 29%

· Married 46.5%

· Civil Partnership 0.4%

· Divorced 11%

· Widowed 8%

No adults using the service are recorded as married; they are recorded as single or the field is blank

We did not receive any feedback from anyone in this protected characteristic.

No adults recorded with this protected characteristic so there is no impact anticipated.

No specific mitigations required at this time.

Armed Forces

In 2021, 21,173 people in East Sussex reported that they had previously served in the UK armed forces (4.6% of usual residents aged 16 years and over).

There were 19,917 households (8.3% of all households) in East Sussex with at least one person who had served in the UK armed forces.

Whilst adults will not have served in the Armed Forces, it is not known whether anyone in their households has.

We did not receive any feedback from anyone in this protected characteristic.

There are no adults within this group.

No specific mitigations required at this time.

Impacts on community cohesion

This proposal affects people living independently in their own homes so no impact is expected on community cohesion.

People responding to the consultation view the service as beneficial for the people receiving support to live more independently, providing them with socialisation, stability, and a feeling of safety.

CSS helps people to access other services and to live more independently as part of their local community.

The revised proposal for ASCH Learning Disability Directly Provided Services to offer a Community Outreach service in place of the current CSS will mitigate these impacts.

No specific mitigations required at this time.

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	74% of the population in East Sussex lives in an urban area with the remaining 26% living in a rural area (2021 census). The supported living schemes are in Eastbourne, Ringmer, Crowborough and Hailsham. Those who access the Community Support Services, but live in the community rather than within one of the four Supported Living schemes live in urban areas across the County. Below is a map of all adults’ home addresses:	We do not have feedback from people living in rural areas.	Transport links and services are less available in some rural areas compared to larger towns, which may reduce the availability and choice of alternative services e.g. personal assistants, daytime opportunities should these be required. Adults who live in rural areas may experience a sense of isolation and social contact.	The revised proposal for ASCH Learning Disability Directly Provided Services to offer a Community Outreach service in place of the current CSS will mitigate these impacts. For the five adults who access services on a Saturday (when services would no longer be provide under the new proposal) we will undertake an ASCH review and support planning exercise, commissioning alternative services to meet needs as required. No specific mitigations required at this time
Carers	There are over 10,000 persons claiming Carer’s Allowance (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 because many carers are hidden.	Almost a quarter (24%) of respondents to the consultation look after, or give any help or support to someone because of their long-term or mental health conditions or illnesses, or problems related to old age. Family and carers of those receiving support get valuable respite from the service. If the service stopped it would increase the workload on them, particularly if the alternatives weren’t suitable.	Carers of working age who are employed may be negatively impacted; this may result in carers not being able to maintain their current employment and potentially experience a reduction to their income. This proposal will not impact carers as much as others within Learning Disability DPS as it predominantly affects people living independently in their own home.	The revised proposal for ASCH Learning Disability Directly Provided Services to offer a Community Outreach service in place of the current CSS will mitigate these impacts. For the five adults who access services on a Saturday (when services would no longer be provide under the new proposal) we will undertake an ASCH review and support planning exercise, commissioning alternative services to meet needs as required. Any carers impacted by the new model of service provision will be offered a Carers assessment/ review.
Other groups that may be differently affected (including but not only: homeless people, substance users, care leavers – see end note)	East Sussex is the 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.	Wealden Citizens Advice were concerned that benefit income is not sufficient to cover the costs of private sector assistance and those who work already have additional pressure from the cost of living, let alone paying for more expensive care.	According to research by British Association of Social Workers (2023) people with a learning disability are likely to be at higher risk of the potential health risks and consequences of cold weather and fuel poverty than the general population. So it is more likely that those affected by this proposal are on lower incomes.	The revised proposal for ASCH Learning Disability Directly Provided Services to offer a Community Outreach service in place of the current CSS will mitigate these impacts. For the five adults who access services on a Saturday (when services would no longer be provide under the new proposal) we will undertake an ASCH review and support planning exercise, commissioning alternative services to meet needs as required. Learning Disability England has been running a cost of living hub . There is information on resources, campaigns, advice on staying warm & financial help in there.

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)

The majority of people responding to the consultation disagree with the proposal to close the community element of the Community Support Service, although a quarter of survey respondents did agree with the proposal. People told us that they are concerned about where people would get alternate support and disagree with the use of private organisations. Key messages from the public consultation were the likely detrimental impact upon the physical and mental health of people using the services and their carers; concerns about the availability of suitable, affordable alternatives; people with learning disabilities can find change harder to cope with and there may be a potential loss of independence.

For people living independently in their own home, if the original proposal went ahead we would find people an alternative service, most likely from the independent sector, who could support them instead. This might be through recruiting a Personal Assistant or using home care service providers. There would be support from our care management teams in adult social care to do this, although it may be harder to find services that suit people’s needs in the same way. Services might also not have availability at the specific times that people want.

For people in supported living, if the original proposal went ahead, people would have all their support needs met by the team based at their supported living property at Field Cottage, Park Lane, the Ferns, or the Martins. There might be changes to the number of staff working at the property and who supports them. These adults in supported living should not be affected as their support would be provided by staff who they already know and work with. In the long term, the change is likely to improve the consistency of care and offer a better service for residents. The main impact would therefore be the uncertainty involved in making the change.

The family and carers of adults could be affected by the original proposal, even if their loved ones’ are living independently.

The revised proposal for ASCH Learning Disability Directly Provided Services to offer a Community Outreach service in place of the current CSS will mitigate these impacts.

All people who are affected would be offered an individual review to consider whether their support package, in light of service changes, continues to meet their assessed needs. Where it is deemed that the services directly provided by Adult Social Care are not sufficient to meet the assessed needs of individuals, Care Managers will seek alternative support solutions. The ongoing impact on people will be monitored via the usual reviews.

There will be as much notice as possible to allow consultation and time for adjustments to changes to be made.

We will communicate changes to adults and their parents/carers appropriately and will work with them to identify action needed. Options may include information and advice about alternative services where available as well as referral to advocacy services. Communications’ preferences will be met via the following options:

· Easy read communications;

· Easy read posters giving details of Advocacy support and scheduled Advocacy meetings;

· Any consultation meetings for parents/carers will be scheduled to take place both during the day and in the evenings to provide flexibility for people who work during the day. Meetings will be held in a range of venues across the county;

· Information accessible to those with sensory impairments.

To ensure existing and future service provision continues to meet the needs of those coming through from Children’s Services, we will work closely with the Transitions team.

The revised proposal, designed to mitigate risks and issues identified via this Assessment and the consultation, will see the service redesigned to a community outreach offer (outlined above), The revised proposal would address the challenge in re-commissioning support currently provided by CSS.

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)
Insert details of consultation when known. This will include input from the Involvement Matters Team.
Inclusion Advisory Group (direct engagement) the proposal was presented on this date and any relevant feedback from members is included in the EqIA.	22/10/2024
Disability Rights Reference Group (direct engagement) the proposal was presented at this meeting and any relevant feedback from members is included in the EqIA.	18/10/2024
Disabled users access to and use of communication devices and services Research summary: Learning disability (Ofcom 2019)
East Sussex in Figures – Data Observatory – Welcome to East Sussex in Figures
Spotlight on Poverty: People with Learning Disabilities \| BASW
Learning Disability - Health Inequalities Research \| Mencap

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
All	Individual reviews of adult’s support needs will be offered to anyone impacted by the new service model. Where the new support model does not meet people’s assessed needs we will commission alternative support e.g. for people using the service at weekends.	Support plans updated to reflect changes in services.	Care and support needs continue to be met.	To reflect implementation of savings’ proposals (all actions).
All	A transition plan is proposed to ensure that all adults experience a consistent level of support. As reviews identify alternative provision, adults will be supported in the transition to their new service.	As above.	As above.	As above.
Disability	Consultation, information, and guidance to be provided in accessible formats appropriate to individual communication needs as required (such as Easy Read).	Adults and carers have input into changes to services.	Care and support needs continue to be met.
Disability	Where necessary new solutions would be sought through the use of Direct Payments which can be used flexibly and adults would be supported to make choices and decisions about available options.	Support plans updated to reflect changes.	As above
Sexual orientation	Improve data collection on sexuality	Better information on sexual orientation of people with a learning disability	Better dataset on this characteristic	From March 2025

Title of Project/Service/Policy	Community Support Services (CSS)
Team/Department	Learning Disability Directly Provided Services
Directorate	Adult Social Care and Health (ASCH)
Provide a comprehensive description of your Project (Service/Policy, etc.) including its Purpose and Scope	Summary of changes to original proposal The original proposal was to stop providing the community support service in people’s own homes and restructure the Supported Living service to meet the needs of adults in these settings with alternative provision found for people that would no longer receive community support. As a result of the consultation processes, the original proposal has been reviewed and a revised proposal has been recommended. The EqIA and consultation process highlighted that whilst having a Personal Assistant (PA) might be the most appropriate alternative to CSS for many people, the PA market has not developed as was hoped. As a result there is a concern that it would not be robust enough to meet the demand created by ceasing CSS support. Under the revised proposal the existing CSS offer would still be stopped; however, the support for these adults could be re-provisioned within Learning Disability Directly Provided Services. In particular, East Sussex County Council would establish a new Community Outreach offer operating from the existing Day Service hubs at Beeching Park in Bexhill and St Nicholas in Lewes. This EqIA, therefore, now considers the impact of the revised proposal including comparing the impact of the new proposal when compared to the initial proposal. This could provide a Monday to Friday provision between 09:00 hrs and 18:00hrs. This would ensure that the assessed care needs of the adults impacted by the proposed closure of CSS fieldwork would continue to be met and the adverse impact of this model would be less than the original proposal. While CSS is notionally available between 07:00hrs and 22:00hrs, 7 days a week, the current delivery is between 09:00 and 17:00. This aligns with what is proposed in the new Community Outreach model offer. There are five adults accessing some of their support at weekends and these people would still be impacted by this proposal as the proposed model would only operate on weekdays. For these people we would review their support plan and either change the day they receive support or identify an alternative. To mitigate the impact these people will be supported to adjust to any changes. This proposed model would achieve the savings required to contribute to the funding gap while ensuring care and support needs could be met and minimising the disruption caused to most adults accessing the service. Original proposal East Sussex County Council (ESCC) is facing a financial gap of £55million next year. This is the difference between the funding available and the cost of keeping services at their present level. We have developed a savings plan that sets out how we will close the funding gap. Where the proposals include significant changes to services there will be a public consultation on the area. The services that are managed within Learning Disability Directly Provided Services support over 500 adults across East Sussex. This support is offered in a number of different service areas: day services, community support services, respite services, Shared Lives and supported accommodation. As part of the original savings plan there was a proposal to stop providing community support services (CSS) where it is delivered to adults in their own homes and re-structure the Supported Living service to meet the needs of adults supported in these settings. For adults we would no longer support, external providers would be identified. Currently, East Sussex Community Support Service (ESCSS) has two elements to the service provision, Supported Living and Community Support Service. Supported Living (SL) has four services where adults live in a setting specifically for adults with a Learning Disability and Community Support Service (CSS) provides support to adults that live in their own home. The model in Supported Living is adults receive their core support from within the service and additional hours are provided by CSS. This means CSS provide support to people who live completely independently along with support to people in our own supported living services. The original proposal was to re-model our Supported Living service so that adults living in that setting received all their support from within their service rather than it being split between SL staff and CSS staff. The original proposal was to end the part of CSS that provides support for adults living independently – these packages of care would be re-commissioned to be provided by the independent sector either through Personal Assistants (PA’s) or Domiciliary Care Providers. CSS support sixty-two adults. Of these, thirty-five live independently and twenty-seven live in our supported living services. Only those adults living independently would be affected. There is a risk that the independent sector doesn’t have the right type of support at the times required by these adults in independent settings supported by Community Support Service. Adults with Learning Disabilities and their Carers will be affected by this proposal. We received one hundred and fifty-seven responses to this consultation.