Equality Impact Assessment
Equality Impact Assessment (EQIA) aims to make services better for everyone who uses them and for staff. It supports value for money by getting council services right first time.
We use EQIAs to review information, consider potential disproportionate or specific impacts on different people, and then plan actions to reduce or avoid negative impacts and create positive outcomes[1]. EQIAs help the Council make good decisions for people who use our services, staff and residents, and to evidence how we have met our duties under the Equality Act 2010[2].
EQIAs need to be done whenever a service, project, policy, strategy, activity or proposal is being started, needs to change, or is being reviewed: if there is potential for an impact on people, then do an EQIA. The actions that emerge from an assessment are then embedded in the relevant action plan to get the best outcomes for the Council, its staff and people who use our services[3].
This template sets out how to complete an EQIA. Guidance for sections is in italics in each section and in the end-notes. If you have any questions about your EQIA and/or how to complete this form, please use the contact details at the end of this form.
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Title of Project |
Review of charging for care and support policy and procedures. |
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Team/Department |
Financial Services, Adult Social Care and Health |
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Provide a comprehensive description of your project (or service/policy, etc.) including its purpose and scope |
The ESCC Charging for care and support policy applies the national legislation in the Care Act 2014 at a local level. It governs the ESCC financial assessment process and provides the framework which ensures the legislation is applied appropriately and consistently for adults who have had care and support services arranged by East Sussex. This policy has not been fully revised since before the introduction of the Care Act 2014, which came was enacted in 2015, so is due for a review.
The Financial Assessment process, governed by this policy, is vital to ensure the ongoing function of Adult Social Care services. The process sets individual assessed contributions and therefore generates significant income for the council. For context, the income that is generated from non-residential assessed contributions across the 24/25 financial year is £18 million. This rises to around £50 million per year if residential assessed contributions are also included. This shows the importance of ensuring a robust policy is in place to govern this process and ensure that charges are correctly applied.
ESCC Legal Services undertook a high-level review of the charging policy in 2020, in response to a legal case against another LA and whilst the policy was deemed it lawful, it was recommended that a full review was undertaken, in particular to review: · The use of the Standard Weekly Charge (SWC) approach to invoicing. · Ensure Savings Credit Disregards are applied consistently across adults accessing both residential and non-residential care and support. · Update policy wording to demonstrate the effective differences between the ESCC policy and the Norfolk policy, i.e. to illustrate how ESCC’s approach differs in practice from Norfolk’s policy which had been found to be discriminatory. · Ensure individuals are effectively signposted to additional information and support, as required by Section 4 of the Care Act.
Additionally, operational colleagues have identified elements of the current policy and practice that could be improved, including: · The process for calculating spouse allowances, as this is currently labour-intensive and overly generous (compared to other LAs).
An external legal review of the proposed changes listed above was undertaken in June 2025. This supported the proposed changes and recommended that the EQIA continue to be updated and reviewed to ensure that any equality implications were considered, in line with ESCC’s public sector equality duty.
This policy and process review has two main objectives: 1) Reduce risk by ensuring compliance with legislation and case law. 2) Generate income and reduce costs by ensuring processes are as efficient as possible.
The impacts of this project delivery are expected to include: · Through this review of the Charging policy, and implementing the changes outlined in the previous section, ESCC will be able to demonstrate processes comply with all relevant legislation, case law and legal advice. · As a result, this will reduce the risk of legal challenge as a clear legal justification for all aspects of the policy and process will enable robust responses to any queries raised. · Although secondary to the main objective of ensuring legislative compliance, the proposals also present an opportunity for cost-savings (e.g. through increased efficiencies) and income generation (though changes to the calculation of spouse allowances). · Increased efficiency within the service, for example a more streamlined process for spouse allowances and the removal of the standard weekly charging model for invoicing, will allow financial assessments to be completed as quickly as possible, therefore contributing to the overall work to reduce waiting times and meet service KPIs.
Internal stakeholders from across ESCC have been involved in developing these proposals and this EQIA, including: - Financial Assessment and Benefits Team - Service Agreement Team - Engagement and Consultation Team - Policy Unit - Operational teams within ASCH (e.g. Care Management) - Brokerage and Supply Management - Legal Services - Business Services - Shared Care Information Systems (SCIS) Additionally, input has been sought from wider stakeholder groups, such as the Inclusion Advisory Group, and East Sussex Seniors Association. |
1. Update on previous EQIAs and outcomes of previous actions (if applicable)
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What actions did you plan last time? (List them from the previous EQIA) |
What improved as a result? What outcomes have these actions achieved? |
What further actions do you need to take? (add these to the Action Plan below) |
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Age – Details of age appropriate Minimum Income Guarantee (MIG - Local Authority Circular) allowances for each age group were added to the charging policy. |
Greater clarity for adults accessing care and support regarding the allowances that would apply to them based on their age. |
Continue to ensure that age appropriate MIG allowances are clear within the policy and/or supporting documentation (e.g. operational instructions) to ensure that people are treated appropriately according to their age. |
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Disability – The policy utilised standard allowances for Disability-Related Expenditure (DRE) (based on disability benefits received) to ensure that disabled adults were not financially disadvantaged based on costs incurred through their disability or medical conditions. |
Efficient application of DRE quickly within financial assessments, with full assessments available on request, meant that this could be applied quickly for adults. |
As the use of standard allowances for DRE is under review (see separate project documentation and associated EQIA) further action will now be required to ensure that any changes to DRE do not disproportionately impact on any individuals because of their protected characteristics. A separate EQIA is underway focussing on the review of the DRE policy, so this change is outside the scope of this EQIA, however it is recognised that changes to DRE will be referred to within the updated Charging policy. |
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Race/ethnicity – Recommendations were made that all documents relating to the financial assessment process could be translated as required. |
Current data does not record how many translated documents relating to financial assessments have been provided but there have been no recorded issues/complaints where race/ethnicity has prevented an individual from engaging with the financial assessment process. |
It is necessary to ensure that the updated policy and supporting documents continue to be available in other languages and/or could be translated as required. |
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Marriage/civil partnership – The existing policy allows for the provision of a spouse allowance, in appropriate circumstances, when a person is part of a couple living in the same household (whether married/civil partners or co-habiting). For this to be applied the client’s partner needs to be willing to share their financial information. Additional support for benefit maximisation is also offered to the partner should they wish to engage with this. |
Improved information sharing for married and civil partners as well as those cohabiting. |
As the calculation of spouse allowances is one of the specific elements being reviewed as part of this project, it will be necessary to ensure that the updated process is fair and clearly defined within the policy. External legal review of the proposed approach (June 2025) agreed that the updates to non-residential FA spouse allowances calculations were lawful and did not discriminate on the basis of any protected characteristics. |
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Sex/Gender – The previous EQIA found that women were more likely than men to have a dependent child living with them. Care Act guidance outlines an additional allowance where the dependent child is living with a parent, however East Sussex provides discretion in applying allowances where a child’s living arrangements is shared. |
The previous EQIA recommended that this discretion was clearly documented in the policy. |
It will be necessary to ensure that this discretion continues to be clearly documented in the updated policy (this is not one of the elements of process that is specifically under review). |
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Rurality – The previous EQIA found that the existing charging policy considers people’s individual circumstances, e.g. offering assessments equally regardless of where the client lives in the county. However, it was recognised that costs for clients living in rural locations could be higher (i.e. higher transport costs or less support to choose from) and this may need to be reflected in their financial assessment or DRE calculations. |
The previous EQIA recommended that the policy was clear that rurality was considered as part of DRE and financial hardship assessments where there is a barrier due to disability or need. |
It will be necessary to ensure that this continues to be clearly documented in the updated policy. |
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Carers – The previous EQIA noted that Carer's Allowance (CA) is paid to carers who care for someone for at least 35 hours a week where the cared for person receives certain benefits. Not all those who are entitled to the payment receive it (due to the value of other benefits received or if the person cared for is in hospital for example). There are over 10,000 persons claiming CA in East Sussex. (Source DWP Feb 2020) |
The previous EQIA also notes that ESCC do not charge unpaid carers for services provided directly to them. This was in recognition of the work they do and to reduce the risk of any negative impact on them. It was felt that the existing policy had a positive impact on unpaid carers. |
It will be necessary to ensure that this continues to be clearly documented in the updated policy. |
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The previous EQIA did not recommend any specific actions in relation to the following protected characteristics: Gender reassignment, pregnancy and maternity, sexual orientation, impacts on community cohesion, religion or belief. |
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The actions above were taken from the last time an EQIA was completed for this policy (2021). The overall finding of the previous EQIA was that “The [financial assessment] process is highly individualised and seeks to consider each person’s financial and personal circumstances. The Support for Charging Framework provides significant support to individuals, and we are confident our policy is fair based upon the local environment including the financial landscape and demographics of East Sussex”.
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Consider the actual or potential impact of your project (service or policy) against each of the equality characteristics.
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Age - people of all ages are protected under the Equality Act. Consider: older adults, under 5s, transition-aged young people (16-24), working age adults etc. |
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Age |
What do you know? Summary of recent data, census information, research and insight about people who use your services and/or staff |
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.This means that older adults represent a larger proportion of those who draw upon care and support from East Sussex and therefore could be disproportionately impacted by any changes.
Additionally, as people get older, they are increasingly likely to need to draw upon support from Adult Social Care. This means that any changes to the way care is funded/accessed may disproportionately impact this group of older adults. For younger adults who have a disability or long-term condition, they may be in receipt of care and support from ESCC for a longer period and therefore be subject to the Charging policy for a longer period.
The age breakdown for adults for whom non-residential financial assessments have been completed in the past year is shown below. The average age is 67.
The Office of National Statistics (ONS) records the proportion of non-internet users as halving between 2011 and 2018, down from 20% of adults to 10%. of those who are classed as non-internet users, 55% come from adults aged over 75, and 24% of those aged 65 to 74. This needs to be considered when planning communications relating to this change, as relying upon digital methods could exclude a large proportion of the group impacted by any changes. The proposal would be to write to anyone impacted by the changes, as this will involve an update to their financial assessment so they will be provided with an updated FA outcome letter. |
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What do people tell you? Summary of service-user and/or staff feedback |
· It is important that clients are seen as individuals and do not feel stereotyped and/or discriminated against. · It has not yet been possible to gain direct feedback from people who draw upon care and support, however this project has been discussed with stakeholder groups (such as the East Sussex Seniors Association and Inclusion Advisory Group). Additionally, it was requested that proposals were shared with and distributed by partner organisations, for example through the Inclusion Advisory Group, to ensure that this is reflective of the needs of those with this protected characteristic. |
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What does this mean[4]? Impacts identified from data and feedback (actual and potential) |
· It is important that a range of communication methods are used to inform adults of these changes, with a particular focus on written communication (e.g. post) to avoid the risk of digitally excluding adults. · Benefits are age-related which has an impact on charges for care. The Minimum Income Guarantee that ESCC applies is age-related (18 to 24; 25 to state pension age; state pension age and over). This means older people receive a higher allowance within the financial assessment to cover standard living costs. Some benefits are only available to working-age people but not to those who are older and of pension age, these extra benefits or circumstances can increase allowances applied to assessments. · Statistically, those in older age groups are more likely to be on a fixed income, so changes to charges/contributions/fees could have a disproportionate impact on them. This could, in some cases, lead to adults not engaging with care if they feel the cost of support is too high or unaffordable within their fixed income. This could also have an impact on carers/family members if, for example, an adult chooses not to ask ESCC to set up care on their behalf owing to the costs and then family or friends must act as support instead. · The proposed changes to Spouse Allowance calculations could help to ensure that individuals are not discriminated against on the basis of age. Currently, when calculating spouse allowances the State Pension age applicable amount is used, regardless of the age of the spouse/partner being assessed. Whilst this could be seen as overly generous to the individual being assessed, it could also be seen as disadvantaging any other working age adult being assessed financially, in comparison to another working age adult who has a partner above State Pension age. · The change to Savings Credit Disregard could be seen as having an impact on individuals linked to the protected characteristic of age, as it only applies to those who reached pension age prior to 6/4/2016. However, the proposed change is intended to reduce the inequality posed by the current approach, as there are a group of adults who meet the eligibility criteria for age but don’t receive the appropriate savings credit disregard under the current policy. If the policy were updated as proposed then this group would be treated the same as others in the same age cohort, i.e. no longer disadvantaged on the basis of their age. · Whilst the application of savings credit disregards more broadly could be seen to discriminate on the basis of age, as they only apply to those who reached pension age prior to 6th April 2016, this is not based on an internal decision. The applicable age range for savings credit is set in national legislation, i.e. savings credit is being phased out nationally and no longer applies to anyone reaching pension age after the cutoff date in 2016. This is not discrimination arising from ESCC’s policy position but reflects the legal position nationally. One of the changes proposed to the ESCC policy through this work will help to mitigate this as much as possible, by extending the application of the savings credit disregard to an additional group who are above the age threshold but have not previously received this disregard in their financial assessments. |
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What can you do? All potential actions to remove or reduce barriers and increase equality. |
· Continue to ensure that age-appropriate allowances (MIG, SCD etc) are clear within the policy and/or supporting documentation (e.g. operational instructions) to ensure that people are treated appropriately according to their age. · Additionally, care will be taken to mitigate the financial impact of changes, where possible. · Changes will ensure that differences in treatment based on age currently embedded within the SCD approach (i.e. differences between res and non-res application based on age) are removed so that SCD is applied equitably. · Individuals will be signposted to wider financial support information, e.g. through the ESCC website page for fully funding adults, as well as information/groups that may be able to support family members with caring responsibilities. This information has recently been reviewed/updated as part of a different project within ASCH to ensure it is as accessible and up-to-date as possible. · Data will be collected moving forward to record the number of adults cancelling care, particularly when citing cost or unaffordability as the reasons for cancellation. This will enable any links to ages to be identified, i.e. to see if those with this protected characteristic are impacted more than others. |
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Disability - A person is disabled if they have a physical or mental impairment which has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities. Consider: sensory and mobility impairments; fluctuating, recurring or developmental conditions; learning difficulties; mental health; and people with cancer, multiple sclerosis or HIV. Neurodivergence and effects of menopause can also apply. |
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Disability |
What do you know? Summary of 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, the same proportion as in 2011 (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.
Individuals with disabilities and/or chronic health conditions are also disproportionately represented in the group who draw upon support from Adults Social Care, as they are more likely to need care in their day-to-day lives. It is not possible to identify all adults with disabilities from the existing reports on ContrOCC, however of the non-residential financial assessments undertaken in the past year 82% included DRE (5975/7290) so this could be a good estimation of the proportion of adults with disabilities overall.
The ASCH Equalities Dashboard tells us the Primary Support Reason of our clients (PSR). The PSR describes why the individual requires social care support; the primary disability/impairment impacting on the individual’s quality of life and creating a need for support and assistive care. · Learning Disability 17% · Mental Health 11% · Physical Support 56% · Sensory Support 1% · Social Support 1% · Memory and Cognition 14%
However, the proposed changes will apply an equitable process for financial assessments to all adults, which will ensure that their disability is considered as appropriate and any necessary benefits and disregards are included/applied as needed, so it is not expected to have a disproportionate impact on this group. This policy review will align with the project also underway to review disability-related expenditure as part of financial assessments, so is expected to support the impact on those with this protected characteristic. Systems are already in place to support adults with disabilities through the FA process, for example assessments available online, over the phone, through in-person visits (including with support from practitioners if required) or with the support of a friend, family member or advocate to ensure that access to an appropriate FA is available to all, regardless of protected characteristics. |
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What do people tell you? Summary of feedback |
· Carers tell us they sometimes need to be present to support the client to fully engage in the financial assessment and care planning processes. · A longer time may be required to understand and digest information being given and a quiet place to reduce or manage acquired stress. · It is important that clients are seen as individuals and do not feel stereotyped and/or discriminated against. · It has not been possible to gain direct feedback from people who draw upon care and support, however this project was discussed with stakeholder groups (such as the Inclusion Advisory Group. |
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What does this mean? Impacts identified |
· People with certain conditions may find the proposed policy harder to read/understand and/or may find it more difficult but can ask a carer or other representative to respond on their behalf. Additionally, the final policy documents can be translated and will be available in easy-read format to support with this. · The service needs to make appropriate provision for clients with disabilities that aids their understanding of the process whilst not causing undue stress. · Staff need to be trained and supported to recognise mental health and unseen disabilities and make the necessary adjustments to care. |
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What can you do? All potential actions |
· The project team will work with Care Management colleagues to identify options for supporting those who lack capacity to make decisions regarding their care and finances. · The Project team will also work with other local groups/stakeholders who support individuals with disabilities in East Sussex to ensure they are aware of this proposal and can provide feedback before decisions are made. · Follow best practice, informed by other LA’s approaches to supporting those without capacity in this context (information on which was collated at an earlier stage in the project to inform the ESCC decision making process). · Ensure that any carers and/or family/friends who are supporting the adult can also be fully involved in the assessment and care planning process (as appropriate) to make sure the adult is supported to fully engage with the process. · Ensure that any changes to the charging policy consider changes to the Disability-related expenditure policy and process, and any concerns and mitigations from the EQIA for that work. |
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Gender reassignment - In the Act a transgender person is someone who proposes to, starts or has completed a process to change his or her gender. A person does not need to be under medical supervision to be protected |
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Gender Reassignment |
What do you know? Summary of data |
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. The 2021 census found that 1640 residents declared their gender identity was different to that assigned at birth which is 0.4% of the population.
We also know: · People may choose not to divulge this information, so the numbers above may not fully reflect the number of transgender people living in the county. · People do not always identify as the gender they were assigned at birth. · People may have a traumatic history with divulging their gender assigned at birth.
It is not possible to identify specific number of adults to whom this applies from the ContrOCC data or LAS as this information is not recorded as part of financial assessments. |
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What do people tell you? Summary of feedback |
· It is important that clients feel their views are heard. · It is important that clients are seen as individuals and do not feel stereotyped. · It is important that clients are seen as individuals and do not feel stereotyped and/or discriminated against. · It has not been possible to gain direct feedback from people who draw upon care and support, however this project has been discussed with stakeholder groups (such as the Inclusion Advisory Group). |
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What does this mean? Impacts identified |
· Staff must be up to date with their Equalities and Diversity training, for example to help prevent unconscious bias. · Staff should not be hesitant in discussing client’s preferences as part of any contact with individuals accessing ESCC services, for example within the financial assessment process. |
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What can you do? · All potential actions |
· Offer choice and control for clients wherever possible. · Use the pronouns that the client requests. · Avoid using cis-normative stereotyping. |
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Pregnancy and maternity - Protection is during pregnancy and any statutory maternity leave. |
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Pregnancy and Maternity |
What do you know? Summary of data |
Countywide, 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. However, there is expected to be limited cross-over between those who are pregnant and those who are receiving care and support from Adult Social Care and therefore are impacted by changes to the Charging policy.
It is not possible to identify specific adults to whom who have this protected characteristic from the standard reporting on ContrOCC as this is not recorded. |
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What do people tell you? Summary of feedback |
No concerns have been raised by adults or partners about the impact of these proposed changes in relation to this protected characteristic.
It is important that clients are seen as individuals and do not feel stereotyped and/or discriminated against.
It has not been possible to gain direct feedback from people who draw upon care and support, however this project has been discussed with stakeholder groups (such as the Inclusion Advisory Group). |
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What does this mean? Impacts identified |
It is not expected that the proposed changes to service delivery will have any impact on adults in relation to this protected characteristic. |
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What can you do? All potential actions |
We will ensure that, if any concerns are raised in relation to the impact on this group in the future that the policy be reviewed and adapted accordingly to mitigate these. |
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Race (ethnicity) - This includes ethnic or national origins, colour or nationality, and includes refugees and migrants[5], and Gypsies and Travellers. |
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Race / ethnicity |
What do you know? Summary of data |
88.3% of usual residents of East Sussex said that they belonged to the White English, Welsh, Scottish, Northern Irish or British ethnic groups. 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 and 1.3.% 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%).
We know: · Individuals may require support to engage with services, for example through the offer of translation services. · Additionally, some individuals may feel less represented by existing services and/or may feel they are not appropriate for them on the basis of their race and/or ethnicity.
It is not possible to identify the specific breakdown of race/ethnicity from the standard reporting on ContrOCC as this data is not recorded. |
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What do people tell you? Summary of feedback |
· It’s important that clients feel their views are heard. · It is important that clients are seen as individuals and do not feel stereotyped and/or discriminated against. · Concerns were raised by members of the Inclusion Advisory Group (December 2024) that language and cultural barriers could prevent adults from engaging with service changes, for example prevent them providing feedback on new proposals. Mitigations for this concern are outlined below. |
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What does this mean? Impacts identified |
· Each service user must be treated based on their individual needs. · Clients need access to appropriate advocate and interpreting services as identified at first point of contact. This includes to enable them to engage with the consultation prior to changes being implemented. · The service needs to actively record race/ethnicity to ensure services are appropriately delivered. |
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What can you do? All potential actions |
· Ensure clients are offered advocacy services, where necessary. · Ensure interpreting service needs are identified at point of contact, and people are offered translated versions of the updated policy and supporting documentation, as appropriate. · Ensure that staff engaging with adults directly know how to check records are correct and update them as necessary · Ensure staff ask relevant details from clients · Ensure staff do not make assumptions and allow clients to self-identify race/ethnicity |
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Religion or belief - Religion includes any religion with a clear structure and belief system. Belief means any religious or philosophical belief. The Act also covers lack of religion or belief. |
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Religion or Belief |
What do you know? Summary of data |
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 specifying their religion as Islam, and 6.7% across the whole of England.
Whilst the largest single religious group is those identifying as Christian, we know that East Sussex has a number of people with different religious affiliations and beliefs.
It is not possible to identify the specific breakdown of religion and/or belief within the standard reporting on ContrOCC as this data is not collected. |
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What do people tell you? Summary of feedback |
· It’s important that clients feel their views are heard. · It is important that clients are seen as individuals and do not feel stereotyped and/or discriminated against. |
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What does this mean? Impacts identified |
· Each service user must be treated based on their individual needs. · Clients may need access to appropriate advocate and interpreting services, and this should be identified at first point of contact. · The service may need to actively record religion and/or belief moving forward to ensure services are appropriately delivered. |
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What can you do? All potential actions |
· Ensure clients are offered advocate/interpretation services as required. · Ensure interpreting service needs are identified at point of contact and clients are offered, where appropriate, translated versions of the updated policy and/or supporting information. · Ensure that staff engaging with adults directly know how to check records are correct and update them as necessary. · Ensure an individual’s beliefs and spiritual needs are considered as part of their financial assessment (for example as part of allocating DRE). · Ensure staff ask relevant details of client. · Ensure staff do not make assumptions and allow clients to self-identify religion/belief. · This has identified a need to improve the data available; this is being addressed through our operational teams which includes action on how we improve collecting data to ensure equalities impacts can be fully considered moving forward. |
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Sex - women and men are protected under the Act. |
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Sex |
What do you know? Summary of data |
Of the population of East Sussex, 299,064 (52%) are female and 270,788 (48%) are male.
We also know: · People do not always identify as the gender they were assigned at birth. · We know that biological sex does not fall into two categories (i.e. Intersex).
According to ASC Equalities Dashboard (September 2021) 58% of clients receiving Long Term Support are female and 42% are male. Females are more likely to live longer and more likely to receive Long Term Support.
Across active non-residential financial assessments, there are significantly more females than males, see breakdown below. Whilst the proposed changes do not directly impact people based on their sex, we recognise that the data shows there is not an equal spread within this cohort as almost 2/3 of the individuals who could be impacted by these potential changes are women.
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What do people tell you? Summary of feedback |
No concerns have been raised by adults or partner organisations about the impact of these proposed changes in relation to this protected characteristic.
It is important that clients are seen as individuals and do not feel stereotyped and/or discriminated against. Additionally, this project has been discussed with stakeholder groups (such as the Inclusion Advisory Group and East Sussex Senior’s Association). |
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What does this mean? Impacts identified |
As women live longer on average, they are more likely to draw upon support from Adult Social Care and for a longer period. This means that changes to the financial assessment and charging processes could have a more significant impact on them.
Men are also less likely to have a dependent child live with them and are more likely to pay Child Support Allowance. Women are more likely than men to have a dependent child living with them. Currently Care Act guidance provides an additional allowance where the dependent child is living with a parent, however East Sussex provides discretion in applying allowances where a child’s living arrangements are shared. It will be necessary to ensure this discretion continues to be recorded within the updated policy. |
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What can you do? All potential actions |
We will ensure that, if any concerns are raised in relation to the impact on this group in the future that the policy be reviewed and adapted accordingly to mitigate these. |
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Sexual orientation - The Act protects bisexual, gay, heterosexual and lesbian people. |
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Sexual orientation |
What do you know? Summary of 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). According to the 2021 Census 3.3% of East Sussex residents declared themselves as LGB+.
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%). This could mean that this group is disproportionately represented amongst those who need to access care and support from the local authority.
It is not possible to identify details regarding their sexual orientation from the standard reporting on ContrOCC as this data is not recorded. We do know that LGBTQ+ adults are statistically less likely to have children and are more likely to be living alone, which means they may not be able to draw upon the support of children or close family to assist them with sourcing and setting up care, which in turn means they be more likely to require the support of ESCC to do so. |
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What do people tell you? Summary of feedback |
· Some people are happy to divulge this information, whilst others are not, particularly as they may feel that this is not relevant to their financial assessment. This could have an impact on their financial assessment, for example if their partner is mistaken for a friend and they would then be eligible for a spouse allowance, so it may be relevant for this data to be requested by the financial assessor. This will not be a requirement of the assessment though and is not required should the individual not wish to share this information. · It is important that clients feel their views are heard, if they choose to share this information. · It is important that clients are seen as individuals and do not feel stereotyped and/or discriminated against. |
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What does this mean? Impacts identified |
Staff must not make assumptions about someone’s sexual orientation, for example based on someone’s appearances or other interactions staff have with them. |
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What can you do? All potential actions |
· Ensure all staff have completed equality and diversity training, to help prevent unconscious bias. · Avoid using hetero-normative stereotyping. |
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Marriage and civil partnership - Only in relation to due regard to the need to eliminate discrimination. |
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Marriage and Civil Partnership |
What do you know? Summary of data |
According to the 2021 census data for East Sussex: · Single 29% · Married 46.5% · Civil Partnership 0.4% · Divorced 11% · Widowed 8%
It is not possible to identify the marital status for all adults who have been financially assessed as this is not always recorded on ContrOCC (and is not recorded in 86% of cases on LAS). ContrOCC can give an indication of the type of financial assessment completed (i.e. single or couples assessment) but that does not always align with marital status, as it could be applied if a long-term partner is living in the home but the individuals were not married. For reference 12% of non-residential financial assessments completed in the past year included spouse allowances (863/7290). |
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What do people tell you? Summary of feedback |
· People tell us how they’d like to be addressed. · It’s important that clients feel their views are heard. · It is important that clients are seen as individuals and do not feel stereotyped and/or discriminated against. · Some people are happy to divulge this information, whilst others are not. This could have an impact on their financial assessment, e.g. if they are eligible for a spouse allowance, so it may be relevant for this data to be requested by the financial assessor. This will not be a requirement of the assessment though and is not required should the individual not wish to share this information. |
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What does this mean? Impacts identified |
· People who live together as a co-habiting couple are treated as a couple irrespective of their marriage or civil partnership. This is usually determined by receipt of benefits from the DWP; where a person received benefits for a couple they are assessed on this basis, where benefits are paid as a single person this is the assessment which is completed. · Our policy provides the ability to provide a spouse allowance when a person is part of a couple living in the same household but in order for this to be applied the clients partner needs to be willing to share their financial information. We offer additional support for benefit maximisation for the partner if they choose to engage with this. · Staff must not make assumptions on a person’s marital or civil partnership status. · Individuals should be advised of whether sharing this information could have a positive impact on their financial assessment, e.g. to see if they would be eligible for a spouse allowance. However, they will not be required to share this if they do not wish to. Financial Assessments can be completed without sharing this. |
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What can you do? All potential actions |
· Ensure the updated calculations for spouse allowances are equitable, fully recorded within the policy and shared with individuals at the point of their financial assessment. This is particularly important if there could be a financial benefit to the individual from engaging with a couples assessment/spouse allowance. · Avoid using heteronormative stereotyping. · Ask people how they would like to be addressed. |
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Armed Forces - protected by the Armed Forces Act 2021 which aims to help prevent service personnel, veterans and their families being disadvantaged when accessing public services. The duty applies to specifically housing, education or healthcare functions, but check whether any impacts may apply in your case. |
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Armed forces |
What do you know? Summary of data |
· 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. · East Sussex had the 4th highest proportion of veterans in the 16 and over population (4.6%) in the Southeast It is not possible to identify whether adults who have been financially assessed have previously served in the armed forces, as this is not included in the data recorded on ContrOCC. Certain income disregards apply to income received by the Armed Forces Community, such as to the guaranteed income payment paid to injured ex-service personnel and other pensions. |
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What do people tell you? Summary of feedback |
No concerns have been raised by adults or partners (such as the Inclusion Advisory Group) about the impact of these proposed changes in relation to this protected characteristic. · It is important that clients are seen as individuals and do not feel stereotyped and/or discriminated against.
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What does this mean? Impacts identified |
It is not expected that the proposed changes to service delivery will have any impact on adults in relation to this protected characteristic, for example the existing disregards linked with armed forces involvement will continue to be applied. |
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What can you do? All potential actions |
We will ensure that, if any concerns are raised in relation to the impact on this group in the future that the policy be reviewed and adapted accordingly to mitigate these. |
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Impacts on community cohesion –Consider impacts on how groups see one another or how the council’s resources are seen to be allocated. Include opportunities to positively impact on good relations between groups. |
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Community cohesion |
What do you know? Summary of data |
The council has a legal duty to foster good relations between groups of people who share different protected characteristics. Some actions or policies may have impacts – or perceived impacts – on how groups see one another or in terms of how the council’s resources are seen to be allocated. As the Charging policy will be applied equally to all adults during the financial assessment there should be no perceived disparity or inequity of treatment that could damage community cohesion. To support this, the policy could also be made available online so it is transparent how financial assessments are conducted. |
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What do people tell you? Summary of feedback |
This project has been discussed with stakeholder groups (such as the East Sussex Senior’s Association and Inclusion Advisory Group and no concerns were raised regarding any potential impact on community cohesion.
We will ensure that, if any concerns are raised in relation to the impact on community cohesion in the future that the policy be reviewed and adapted accordingly to mitigate these. |
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What does this mean? Impacts identified |
No impacts have currently been identified in relation to community cohesion. |
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What can you do? All potential actions |
Any changes to the Care and support policy will be communicated to adults who draw upon ASCH services clearly (i.e. through updated FA outcome letters if there will be any change to their client contribution), i.e. to enable ESCC to maximise the effectiveness of the funding it has available to support as many people as possible in the fairest possible way (i.e. to calculate what individuals can appropriately pay towards their care). |
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Additional categories
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Rurality - issues can include isolation, access to services (e.g.: GPs, pharmacies, libraries, schools), low income / part-time work, infrequent public transport, higher transport and fuel costs and lack of affordable housing. Deprivation can be more dispersed and less visible. |
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What do you know? Summary of data |
74% of the population in East Sussex lives in an urban area with the remaining 26% living in a rural area (2021 census).
It is not possible to identify whether those individuals who have been financially assessed live in rural or urban areas as this data is not available explicitly on ContrOCC. Address data for individuals is known, however this does not define whether this is a rural or urban location so these criteria would need to be defined. |
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What do people tell you? Summary of feedback |
No concerns have been raised by adults or stakeholders about the impact of these proposed changes in relation to this protected characteristic. Financial assessments are undertaken for adults who live countywide and their location does not impact this. Most assessments are undertaken using online information and/or over the phone, but assessment officers can visit adults anywhere in the county to undertake assessments if needed.
However, there is a risk that living in a rural area could make it more difficult/expensive to source care and could lead to increased care costs for adults living in these areas. Additionally, there is an increased risk of digital exclusion for those living in rural areas, for example from poor mobile and internet signal, which in turn could make it more difficult for these adults to engage with the financial assessment process.
This project was discussed with stakeholder groups, such as the Inclusion Advisory Group and East Sussex Seniors Association. The IAG mirrored concerns that rurality could make it more difficult for individuals to engage with the FA process and also could lead to them having higher costs. The mitigations for these risks are: 1) that assessments are offered in a variety of ways (phone, online, paper and in-person) to enable people to engage with the process effectively in both urban and rural parts of the county and 2) that higher costs could be considered under DRE within a financial assessment if someone faces higher costs relating to their disability/medical needs from living in a rural area (e.g. higher heating or transport costs). |
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What does this mean? Impacts identified |
It is not expected that the proposed changes to service delivery will have any impact on adults in relation to this protected characteristic. |
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What can you do? All potential actions |
Ensure rurality is considered as part of DRE and financial hardship assessments where there is a barrier due to disability or need. Offer financial assessments in the most appropriate form for each individual, i.e. using online or phone methods if appropriate or offering an in-person visit if required owing to their rural location.
We will ensure that, if any concerns are raised in relation to the impact on this group in the future that the policy be reviewed and adapted accordingly to mitigate these. |
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Carers - A carer is anyone, of any age, who looks after a family member, partner or friend who needs help because of their illness, frailty, disability, a mental health problem or an addiction and cannot cope without their support. The care they give is unpaid. |
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What do you know? Summary of data |
There are over 10,000 individuals claiming Carers 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 of carers because so many carers are hidden.
It is not possible to identify the specific number of carers that could be impacted by this specific proposal from the ContrOCC data. This is because it is not clear from the standard financial assessment reporting if those who have been financially assessed are supported by family and/or friends in a caring capacity. However, for reference, the reporting shows that 7% of non-residential financial assessments completed in the past year included a disregard for carers allowance (538/7290). |
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What do people tell you? Summary of feedback |
It has not yet been possible to gain direct feedback from people who draw upon care and support, however this project has been discussed with stakeholder groups (such as the East Sussex Senior’s Association and the Inclusion Advisory Group) and no specific concerns were raised. |
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What does this mean? Impacts identified |
Through a combination of disregarding carers allowance within financial assessments and from not charging unpaid carers for services provided directly to them, it expected that this policy will continue to have a positive impact on carers (as is the case with the existing policy). The potential impact will be fully explored through the public consultation in case any additional impacts are identified. |
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What can you do? All potential actions |
Individuals will be signposted to wider support information, such as information/groups that may be able to support family members with caring responsibilities in the event that these proposals mean that individual carer’s require additional support. We will ensure that, if any concerns are raised in relation to the impact on this group in the future that the policy be reviewed and adapted accordingly to mitigate these. |
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People with care experience |
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What do you know? Summary of data |
Not known – It is not possible to identify this from current data, as the report from ContrOCC does not record whether an individual has previously received care from ESCC (i.e. is “care experienced”). |
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What do people tell you? Summary of feedback |
No concerns have been raised by adults or partners about the impact of these proposed changes in relation to this protected characteristic. |
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What does this mean? Impacts identified |
It is not expected that the proposed changes to service delivery will have any impact on adults in relation to this protected characteristic. |
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What can you do? All potential actions |
We will ensure that, if any concerns are raised in relation to the impact on this group in the future that the policy be reviewed and adapted accordingly to mitigate these. |
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Other people that may be differently affected - this will vary by service, but includes people who: · are homeless or in insecure housing, · in prison, · with low levels of literacy, · are digitally excluded, · experiencing or in recovery from drug and alcohol addiction (and their families), · have or are experiencing domestic or sexual abuse. |
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What do you know? Summary of 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% across England.
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What do people tell you? Summary of feedback |
No concerns have been raised by adults or partners about the impact of these proposed changes in relation to the above groups.
It has not yet been possible to gain direct feedback from people who draw upon care and support, however this project has been discussed with stakeholder groups (such as the East Sussex Senior’s Association and the Inclusion Advisory Group) and no specific concerns were raised. |
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What does this mean? Impacts identified |
It is not expected that the proposed changes to service delivery will have any impact on adults in relation to this protected characteristic.
This client group falls into the category of ‘seldom heard’, meaning they are less likely to access care and support in line with their needs - this could be due to a lack of fixed address or a lack of trust in services for example. |
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What can you do? All potential actions |
Ensure all communications are as accessible as possible and available in a variety of media. This will include an easy read version of the policy. This will also include printed versions of the policy being made available where appropriate, to ensure no one is digitally excluded from having their voice heard. This can be requested over the phone to FABA or through a care practitioner.
Ensure staff are knowledgeable of partner agencies and services offered in the community.
We will ensure that, if any concerns are raised in relation to the impact on this group in the future that the policy be reviewed and adapted accordingly to mitigate these. |
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Staff impacts: if your proposal affects staff, have you consulted with the Staff Networks? (contact details are on the equality pages of the intranet: search for ‘staff networks’) |
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N/A - no expected impact on staff roles or responsibilities. No changes to staffing structures or responsibilities. Staff have been consulted on the required changes to internal processes that would be required to implement this project. This has been reflected within the options papers accordingly. |
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Assessment of overall impacts, summary of actions and any further recommendations |
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· Risk that policy document cannot be accessed by some individuals to whom it applies, e.g. owing to language barriers or disabilities. o Mitigation is to ensure that the policy updates are accessible and can be accessed in a variety of forms, media and languages (as appropriate). o Support from Care Management colleagues to identify individual needs and signpost translation services or alternative media for policy or leaflets as necessary. · Risks of disproportionate impact on older adults accessing services. o Mitigation is to ensure charges are applied on the basis of financial assessment outcome, i.e. not linked with age. o Policy development to ensure that people are no longer treated inequitably on the basis of age (i.e. through the changes to application of SCD and by ensuring age-appropriate applicable amounts are used as the basis for SA calculations being proposed in this policy change). o Additionally, the proposed changes will be reviewed by partner organisations supporting older adults in East Sussex, and the ESCC-led East Sussex Senior’s Association, to help identify any further risks and mitigations. · Risks of disproportionate impact on females accessing services. o Mitigation is to ensure charges are applied on the basis of financial assessment outcome, i.e. not linked with gender. o Additionally, the proposed changes will be reviewed by partner organisations supporting all genders in East Sussex, i.e. through the Inclusion Advisory Group, to help identify any further risks and mitigations. · Risk from limited data, i.e. not able to identify risks to specific groups. o Mitigation is to seek additional data, where available and appropriate, to inform this proposal such as through external stakeholder groups. |
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Source and type of data (e.g. research, or direct engagement (interviews), responses to questionnaires, etc.) |
Date |
Gaps in data (were there any people you didn’t hear from? Does research include information on all characteristics?) |
Actions to fill these gaps: who else do you need to engage with? (add these to the Action Plan below, with a timeframe) |
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Research on approach taken by other LAs |
Oct-Dec 2024 |
Data sampled from more than 20 LAs, however this does not necessarily reflect the approach taken by all LAs nationally. |
Additional data collated from NAFAO and other LA consultations to help ensure that the data was as representative as possible of approaches taken by other LAs. |
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EQIAs and consultations from other LAs who have implemented changes to their charging policy and approach |
Oct-Dec 2024 |
Only able to collate data from consultations and EQIAs that were available publicly, or from LAs who responded to the request to share information. |
Contacted LAs again who have recently consulted on this type of change to request they share their consultation reports and EQIA to inform ESCC approach. |
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Data on individuals with active financial assessments (ContrOCC, Infoview) |
Oct-Dec 2024 |
Limits to exported data, i.e. unable to show ethnicity, religious beliefs or sexual orientation |
Using census data and other available methods to identify impact on these groups. |
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Proposed changes shared with stakeholder groups (Inclusion Advisory Group, Disability Rights Reference Group, East Sussex Senior’s Association) to request feedback on the proposals. |
December 2024, ESSA May 2025 |
Limitation of engaging with stakeholder groups, rather than the full cohort, so data can only be representative of feedback from those who could be impacted. |
Asked stakeholder groups to share information with members and/or through their wider networks to collect broader feedback. |
4. Prioritised Action Plan
NB: The Council’s duties are ongoing: impacts must be kept under review. Actions need to be implemented and if significant changes occur further assessment may be needed.
Transfer these actions to service or business plans and monitor to ensure they achieve the outcomes identified. Your departmental equality lead will follow up at an agreed time to ensure actions are being implemented.
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Impact identified and group(s) affected |
Action planned |
Expected outcome |
Measure of success |
Timeframe |
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AGE: Potential to disproportionately impact on those who are older, as 58% of the adults to whom these changes could apply are 65+ (average age is 67). This could mean that changes have a disproportionate impact because of age. Additionally, those over retirement age are statistically more likely to be on a fixed income so changes to their assessed contribution could have a more significant impact on their remaining funds. |
Ensure that financial assessments are conducted equitably for all, regardless of age.
Adults of any age can request an updated financial assessment if they feel that their situation has changed, and their charges need to be recalculated.
Individuals will be signposted to wider financial support information, e.g. through the ESCC website page for fully funding adults, as well as information and groups that may be able to support family members with caring responsibilities. Individuals will also be signposted to wider support available to help with identifying and arranging appropriate care and support, such as the directory available through Care Choices.
Ensure spouse allowance calculations are based on age-appropriate applicable amounts, rather than always using pension age values regardless of age, to ensure this does not inadvertently discriminate against other working age adults. |
Ensure that appropriate disregards are applied for adults on the basis of their age to maximise their available funding in line with the updated charging policy.
Ensure that the appropriate applicable amount is used, based the age of the partner/spouse, as part of future spouse allowance calculations.
Allow a grace period of 3 months to help mitigate the impact of increased client contributions to any individuals who are impacted by changes to the spouse allowance calculations. This will allow them time to budget for the impact of any changes to their assessed contribution. |
The policy will ensure that all adults, regardless of their age, are left with the correct age-appropriate Minimum Income Guarantee (MIG). |
Ongoing |
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AGE: Help to mitigate financial impact of changes, particularly on groups with fixed incomes (such as those above retirement age), by promoting benefits maximisation. |
The Department of Health and Social Care’s guidance states that a person will have their benefits maximised at the same time as the means tested assessment is carried out. Within the Financial Assessment, Financial Assessment Officers will help adults to identify any benefits they may be entitled to that they are not claiming and receive the correct advice and information on how to claim, which may include signposting to the relevant organisations. |
Having benefits maximised helps with a person’s overall wellbeing, reducing stress etc. This could also help to ensure that individuals have sufficient income to pay for care as well as the new proposed costs if they are claiming all that they are entitled to. |
Increased benefits being claimed by adults (as appropriate) |
Ongoing. |
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GENDER: Gender imbalance in target cohort (62% female) means that there is the potential to disproportionately impact women if changes are introduced. |
Ensure financial assessments are completed equitably for all adults to avoid any discrimination based on gender.
Adults of any gender can request an updated financial assessment if they feel that their situation has changed and their charges need to be recalculated.
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Apply the updated charging policy to all adults as part of their financial assessments, regardless of gender. |
The policy will ensure that all adults, regardless of their gender, have had an individualised financial assessment which takes account of their specific circumstances (including gender as appropriate) and have an assessed contribution which aligns with their financial situation. |
Ongoing |
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ALL: People are asked about their demographic information and are supported regardless of how they identify. |
Ensure all staff are encouraged to complete Diversity and Equality Training |
Adults will feel accepted and respected.
Diversity and Equality Training will lead to a change of thinking and behaviours of staff, which will have a positive impact on the experience of adults accessing services. |
The client will be fully able to participate in the financial assessment process.
Number of staff undertaking Diversity and Equality Training. |
Ongoing.
Analysed yearly in April. |
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ALL: Ensure consultations and policy changes are accessible and applicable to those with all protected characteristics. |
Ensure interpreting service needs are identified at point of contact and that any policy changes can be available in a range of languages and Easy Read format, as required.
Ensure proposal is discussed with stakeholder groups representing members of the community- including the Inclusion Advisory Group, The Disability Rights Reference Group and the East Sussex Seniors Association, to enable any additional impacts links to protected characteristics to be identified. |
All adults will be fully able to participate in the financial assessment process, understand what charges apply and agree to these. |
The client will be fully able to participate in the financial assessment process.
Increased use of ESCC Translation and interpretations services (as required) |
Ongoing
Stakeholder engagement completed. |
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All: Ongoing engagement with service users |
Service user feedback will continue to be collected by Financial Services, for example through the FABA survey to inform service delivery. |
Feedback from service users is used to identify gaps in provision and good practice. |
A range of service users provide regular feedback.
Protected characteristics are collected within this feedback (where appropriate) to identify if there are any gaps in service provision for specific groups.
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Ongoing.
FABA survey to be revisited annually (TBC) |
EQIA sign-off: (for the EQIA to be final the following people must review and agree it)
Staff member competing Equality Impact Assessment: Ben Baker Date: 31/7/25
Directorate Management Team rep or Head of Service: Sonny Butler Date: 31/7/25
Equality lead: Sarah Murray Date: 31/7/25
Guidance end-notes
[1] EQIAs are always proportionate. The greater the potential adverse impact on a protected group (e.g. disabled people), the more thorough our process must be. Consider:
[2]Our duties in the Equality Act 2010
Under the Equality Act 2010 we have a legal duty to demonstrate that we have identified and considered the actual and potential impact of our activities on people who share any of the legally ‘protected characteristics’: age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation, and marriage and civil partnership. This applies to policies, services (including commissioned services), and our employees. This template provides evidence of this consideration.
In the Act we must give ‘due regard’ (pay conscious attention) to the need to:
[3] The following principles, drawn from case law, explain what we must do to fulfil our duties under the Equality Act:
· Knowledge: all Council employees must be aware of our legal duties and comply with them appropriately in our daily work.
· Timeliness: assessment must be completed and considered at the time a decision is taken – not afterwards.
· Real Consideration: the duty must be an integral, rigorous part of your decision-making process and influence the process.
· Sufficient Information: you must assess what information you have and what more is needed to give proper consideration.
· No delegation: the Council is responsible for ensuring that any contracted services, which are provided on its behalf, can and do comply with these legal duties.
· Review: this continuing duty applies when you develop/agree a policy or service and when it is implemented and reviewed.
· Proper Record Keeping: you must keep records of the process, the impacts and the actions that you will implement.
[4] Your EQIA must get to grips fully and properly with actual and potential impacts. Our legal duties to identify equality impacts don’t stop us taking decisions, or introducing changes that are needed. They do require us to take decisions and make changes conscientiously and deliberately confront the anticipated impacts on people.
[5] Refugees and migrants means people whose intention is to stay in the UK for at least one year (excluding visitors, short term students or tourists). This definition includes asylum seekers; voluntary and involuntary migrants; people who are undocumented; and the children of migrants, even if they were born in the UK.