Equality impact assessment (EIA) form: evidencing paying due regard to protected characteristics

(Form updated October 2023)

 

Domestic Abuse Policy for the Housing Service

 

If you would like this information in another language or format such as Braille, large print or audio, please contact the Communications Unit on 01609 53 2013 or email communications@northyorks.gov.uk.

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Equality Impact Assessments (EIAs) are public documents.  EIAs accompanying reports going to County Councillors for decisions are published with the committee papers on our website and are available in hard copy at the relevant meeting.  To help people to find completed EIAs we also publish them in the Equality and Diversity section of our website.  This will help people to see for themselves how we have paid due regard in order to meet statutory requirements. 

 

Name of Directorate and Service Area

Community Development

Housing Service

 

Lead Officer and contact details

Jo Marriott

Domestic Abuse Housing Alliance Officer

 

Names and roles of other people involved in carrying out the EIA

 

 

 

How will you pay due regard? e.g. working group, individual officer

The Domestic Abuse Housing Alliance Strategic Board will monitor the introduction and embedding of the new policy.

 

We are seeking accreditation through the Domestic Abuse Housing Alliance who will independently review our practice.

 

The Housing Management Team will monitor impact in the long-term.

 

 

When did the due regard process start?

We began working towards the accreditation in November 2022 and have been sharing best practice around intersectionality and put a training program into place for all housing staff around domestic abuse awareness.  The training has regard to equalities and seeks to increase awareness of the diverse and intersecting needs of our residents and tenants.

In November 2023 we started work on the drafting of the new Policy.

 

 

 

 

 

Section 1. Please describe briefly what this EIA is about. (e.g. are you starting a new service, changing how you do something, stopping doing something?)

 

This EIA is in support of the proposed new Domestic Abuse Policy for the council’s Housing Service.  The Housing Service is newly formed from the seven former district and borough housing teams.  There was no common Domestic Abuse Policy in place before local government reorganisation.

The Policy will provide clear guidance to staff and inform tenants of how the council will respond to reports of domestic abuse from council tenants and seek to support people who are affected by it.  It will also include guidance for other staff within the Housing Service who may come into contact with the public and residents of North Yorkshire and be likely to identify domestic abuse.

 

 

Section 2. Why is this being proposed? What are the aims? What does the authority hope to achieve by it? (e.g. to save money, meet increased demand, do things in a better way.)

 

This proposal is responding to the Social Housing Regulation Act (2023) and associated Neighbourhood and Community Consumer Standard which requires local authorities with housing stock in England and Wales to provide information about specialist support agencies to victims of domestic abuse, to consider staff training on how to support people affected by domestic abuse and how to make referrals. The policy will clearly show how the team will respond to reports of domestic abuse and consider the unique needs of individuals including their protected characteristics.

 

The aim is to provide our service in a better way, to help to prevent further harm to those affected by domestic abuse.  By seeking accreditation through the Domestic Abuse Housing Alliance, we are adopting best practice referred to in the Domestic Abuse Statutory Guidance published July 2022.

 

This work is linked to ongoing work undertaken through the North Yorkshire Domestic Abuse Local Partnership Board which sits under the Community Safety Partnership which is a statutory partnership https://www.nypartnerships.org.uk/nycsp .

 

An independent needs assessment and a wider system review was undertaken by the specialist domestic abuse charity SafeLives in 2022 across North Yorkshire and the City of York. The findings from this review informs the new multi-agency Domestic Abuse Strategy which will be published in the next few weeks. Actions from the multi-agency strategy will feed into other council-wide strategies such as those under the Health and Well-being Strategy.  Some of the actions relate to the Housing Service and directly link with this new Domestic Abuse Policy and new ways of working which will result from its implementation.

 

 

Section 3. What will change? What will be different for customers and/or staff?

 

The Policy will provide clear guidance for staff within the Housing Service and a clear message that the council will not tolerate domestic abuse.

 

The Policy will give customers, who are affected by domestic abuse, information about what support they can expect from the council whether they hold a council tenancy or come into contact with Housing staff for any other reason.

 

The Policy will provide consistency across the county.

 

 

Section 4. Involvement and consultation (What involvement and consultation has been done regarding the proposal and what are the results? What consultation will be needed and how will it be done?)

 

In developing this policy, consultation has been carried out with staff in the Housing Service and other parts of the council.

 

Consultation has also been carried out with strategic partners in the county through our Domestic Abuse Local Partnership Board which has a wide membership including statutory agencies such as the police and probation, social housing providers, commissioned services, and charities.

 

Consultation has been carried out with people with lived experience of domestic abuse.

 

The draft policy was sent to many local specialist agencies for comment including those who support people with protected characteristics, those who provide support for people recovering from trauma and people with substance misuse support needs.

 

We also shared the draft policy with the specialists at the Domestic Abuse Housing Alliance and they have given valuable input.

 

We received responses from key staff within the council including specialists in safeguarding, and partner agencies including people with lived experience and have amended the draft policy to include suggestions that they have made.  Amendments include improving the clarity of wording, improving information on support agencies and referral pathways.

Specialist agencies who support victims assisted in suggesting modifications which have been made, to direct staff to help empower people affected by domestic abuse, by providing information including timescales and realistic housing options, so that they can make informed choices about their future.

Amendments were also made to explain more about intersectionality and the gendered nature of domestic abuse.

 

 

 

 

Section 5. What impact will this proposal have on council budgets? Will it be cost neutral, have increased cost or reduce costs?

 

Delivery of the policy will not have an impact on council budgets in the short-term as we are currently in receipt of new burdens funding from central government which was awarded with the introduction of new duties under the Domestic Abuse Act 2021.

 

Part of this funding is being used to provide training for housing staff and a staff resource to work on domestic abuse policy, procedure and sharing good practice within the Housing Service.

 

DLUCH have not yet announced their plans for future funding around domestic abuse post April 2025, however much of the work to embed this policy will have been completed by April 2025.

 

 

 

Section 6. How will this proposal affect people with protected characteristics?

No impact

Make things better

Make things worse

Why will it have this effect? Provide evidence from engagement, consultation and/or service user data or demographic information etc.

Age

 

X

 

The needs assessment found that the age profile of domestic abuse victims is somewhat diverse, people of any age can be affected by domestic abuse.

Training has been designed to inform staff that young people and older people can be affected by domestic abuse.

Police incident reports early this year (2024) show an increase in older people reporting domestic abuse to the police. It remains unclear why there is increase in older victim reporting however, studies recognised that older people are at risk of specific types of domestic abuse such as coercive and controlling behaviour and financial abuse. Further evidence suggests, older people are more likely to normalise abusive behaviour and may not perceive themselves as being a victim due to generational knowledge gap.

The policy should enable domestic abuse victims and survivors of all ages to get access to support more quickly and therefore help reduce future harm.

 

Disability

 

X

 

A needs assessment which looked at the current service provision landscape for safe accommodation shows the number of domestic abuse victims with disability or additional needs has increased. Victims who disclose a mental health illness increased in 2021-22 from an average of 5-7 to 47 percent. This may be partly due to improvements in recording data.  Other national data sources have shown disabled people are twice as likely to experience domestic abuse because of their situational vulnerabilities, which makes them reliant on intimate partners, family members and health professionals for their every need. Through training associated with the implementation of this policy and the accreditation, staff will be better skilled to spot the signs of domestic abuse and respond appropriately when working with people who have a disability.

 

Sex

 

X

 

According to the needs assessment, the gender of victims reporting domestic abuse in North Yorkshire and in the City of York remained fairly consistent across the two years 2019-20 to 2021-22, with between 67% and 68% of identified victims recorded as being female, and between 18% and 19% recorded as male. Across all two years, 5-6% of victims were recorded as unknown, and fewer than 1% of victims were recorded as identifying as non-binary, transgender or other, combined across all two years While domestic abuse can happen to all genders, women are particularly at higher risk. The policy is inclusive of all genders whilst training will acknowledge that domestic abuse is a gendered issue.

 

Race

 

X

 

The multi-agency data examined in the countywide needs assessment showed that over half of all identified victims were of unknown ethnicity, and over 40% identified as White or White British. It should be noted that North Yorkshire Police and some of the localities captured a person’s ethnicity as White but were unable to separate into White British or White other.

 

There is evidence to show that black women are disproportionately affected by domestic abuse and have less confidence to report the abuse to authorities, this policy will improve opportunities to support victims and reduce harm to them.

 

The 2021 census shows that the minority ethnic population in North Yorkshire is around 7% and ethnicity is very diverse.

https://www.communityfirstyorkshire.org.uk/blog/ethnicity-in-north-yorkshire-what-the-2021-census-is-telling-us/

 

One of the larger ethnic groups is gypsy, roma, traveller and showpeople and there are plans to raise awareness of the culture of this group with the housing team.

 

In 2021-22 9.9% of high-risk domestic abuse cases heard at a multi-agency risk assessment conference meetings in North Yorkshire were recorded as non-white British, 6.4% for Selby ranging to 11% in Hambleton and Richmondshire.

 

This new policy and the associated training focus on breaking down barriers for people from minoritized groups so that they are able to access support.  Therefore services should improve for people with lived experience with the protected characteristic of race.

 

Gender reassignment

 

X

 

Information from the needs assessment states only 5-6% of victims who accessed services in the last three years were recorded as gender unknown, and fewer than 1% of victims identified as non-binary, transgender or other. Currently, there are not specific commissioned services for LGBTQIA people locally; however commissioned services are using innovative trauma-informed methods to meet the needs of this group especially those threatened with the potential impact to ‘outing’. The new policy is inclusive and people who have been through gender reassignment should not be adversely affected.  There is new national guidance relating to domestic abuse in the trans community and this will be disseminated to staff.  National specialist support is available for people from this community and staff will be made aware of this.  We therefore anticipate that services will improve for people who have had their gender reassigned.

 

Sexual orientation

 

X

 

National data suggests that LGBTQ+ victims of abuse are more likely than heterosexual individuals to experience abuse from multiple partners, are almost twice as likely to have attempted suicide, are more than twice as likely to have self-harmed and are more than twice as likely to have experienced historic abuse from a family member. Therefore, it is vital that the sexual identity of domestic abuse victims is recorded and understood.  This group has been considered and the policy will address the specific needs of this community.

 

Religion or belief

 

X

 

The traditional relationship dynamic may be different in some cultures, and research shows that people within certain cultures may be more likely to suffer domestic abuse.  This could have several effects including victims being more reluctant to report or resistant to their partner being arrested.

In North Yorkshire there is a diverse community across urban and rural localities. Some residents have recently arrived in the UK and are not familiar with the legal protections afforded to victims of domestic abuse. Therefore, it is important to provide cultural awareness to staff of these communities and ensure that staff are trained about how domestic abuse, honour-based violence, forced marriage and female genital mutilation may occur and how to respond.

 

Training will include awareness raising of cultural issues and the importance of using independent translators when working with victims who do not speak English. We anticipate that the service will improve for people in the category.

Pregnancy or maternity

 

X

 

During pregnancy there can be an increase or escalation in domestic abuse, this poses risks to unborn children and expectant mothers. This policy will improve awareness of domestic abuse and strengthen knowledge of referral pathways so reduce harm.

Marriage or civil partnership

 

X

 

The Domestic Abuse Act 2021 recognises that domestic abuse can occur in a variety of intimate and family relationships and is not limited to persons within a marriage or civil partnership. There will be no detriment to married people or those in a civil partnership.

 

 

 

Section 7. How will this proposal affect people who…

No impact

Make things better

Make things worse

Why will it have this effect? Provide evidence from engagement, consultation and/or service user data or demographic information etc.

..live in a rural area?

 

 

 

X

 

The new policy will improve our services for all residents and tenants including those living in rural areas.

…have a low income?

 

 

 

X

 

The policy will apply to all residents and tenants including those on a low income, an element of domestic abuse can be economic abuse and training will be provided to staff so that they have a better understanding of this.  Economic abuse can have wide-reaching and long-lasting effects (such as bankruptcy) and can be a factor relating to homelessness and debts. By supporting people to obtain specialist support victims and survivors will be in a stronger position to access private rented accommodation and move forward to rebuild their lives.

 

…are carers (unpaid family or friend)?

 

 

X

 

The policy covers all residents and tenants and there will be no detriment to carers.

 

 ….. are from the Armed Forces Community

 

 

X

 

The policy covers all residents and tenants and there will be no detriment to members of the armed forces or their dependents.  Our commissioned support service has special arrangements in place to provide appropriate support for this group as there is a large armed forces community in North Yorkshire.

 

 

 

Section 8. Geographic impact – Please detail where the impact will be (please tick all that apply)

North Yorkshire wide

X

 

Craven

 

 

Hambleton

 

 

Harrogate

 

 

Richmondshire

 

Ryedale

 

 

Scarborough

 

 

Selby

 

 

If you have ticked one or more areas, will specific town(s)/village(s) be particularly impacted? If so, please specify below.

There will be no impact on a specific geographical area

 

 

 

Section 9. Will the proposal affect anyone more because of a combination of protected characteristics? (e.g. older women or young gay men) State what you think the effect may be and why, providing evidence from engagement, consultation and/or service user data or demographic information etc.

 

We are planning to train our staff about intersectionality, and this new policy includes measures to improve the way that we work with customers who have more than one protected characteristic, or more complex needs and may need services to be delivered in a unique way in order to meet their individual needs.  We will consider how staff may need to adapt service delivery to accommodate a person’s neurodiversity.

 

 

 

Section 10. Next steps to address the anticipated impact. Select one of the following options and explain why this has been chosen. (Remember: we have an anticipatory duty to make reasonable adjustments so that disabled people can access services and work for us)

Tick option chosen

1.      No adverse impact - no major change needed to the proposal. There is no potential for discrimination or adverse impact identified.

x

2.      Adverse impact - adjust the proposal - The EIA identifies potential problems or missed opportunities. We will change our proposal to reduce or remove these adverse impacts, or we will achieve our aim in another way which will not make things worse for people.

 

3.      Adverse impact - continue the proposal - The EIA identifies potential problems or missed opportunities. We cannot change our proposal to reduce or remove these adverse impacts, nor can we achieve our aim in another way which will not make things worse for people. (There must be compelling reasons for continuing with proposals which will have the most adverse impacts. Get advice from Legal Services)

 

4.      Actual or potential unlawful discrimination - stop and remove the proposal – The EIA identifies actual or potential unlawful discrimination. It must be stopped.

 

Explanation of why option has been chosen. (Include any advice given by Legal Services.)

 

This policy will improve services and should have no negative impact

 

 

 

 

Section 11. If the proposal is to be implemented, how will you find out how it is really affecting people? (How will you monitor and review the changes?)

 

This Policy will be monitored by Housing Managers and case files audits will be undertaken as part of the Domestic Abuse Housing Alliance accreditation assessment.

 

The Domestic Abuse Housing Alliance Strategic Board will monitor the introduction and embedding of the new policy.

 

Progress will be reported to the North Yorkshire Domestic Abuse Local Partnership Board.

 

 

 

Section 12. Action plan. List any actions you need to take which have been identified in this EIA, including post implementation review to find out how the outcomes have been achieved in practice and what impacts there have actually been on people with protected characteristics.

Action

Lead

By when

Progress

Monitoring arrangements

Case File Audits

 

 

NYC Housing Service

Quarterly

 

Housing Management Team will monitor

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Section 13. Summary Summarise the findings of your EIA, including impacts, recommendation in relation to addressing impacts, including any legal advice, and next steps. This summary should be used as part of the report to the decision maker.

 

This policy has been written with regard to national best practice and in consultation with specialist agencies. Our commitment to work towards accreditation through the Domestic Abuse Housing Alliance and work completed so far, shows that the Housing Service is working to improve our service delivery for people who find it more challenging to access our service and our commissioned services.  We regularly consider how we can work with partner agencies to adapt our provision appropriately to meet the needs of people with protected characteristics.

 

In carrying out this assessment we have found no evidence that any group will be adversely affected by the introduction of the new policy.

 

This policy relates to our new multi-agency Domestic Abuse Strategy, which is soon to be published, the vision statement is shown below: -

 

 

Our vision

‘In North Yorkshire and York, we do not tolerate domestic abuse and we will strive to ensure everyone can live free from abuse and harm. We will work to create an environment where healthy relationships are the norm and where victims/survivors and their children have access to the right support at the right time.

Domestic abuse is everybody’s business, where our partnerships will work collaboratively to create lasting change across all our communities and the voice of the victim is at the heart of our response and where perpetrators of abuse are held accountable for their behaviour’.

 

 

 

 

Section 14. Sign off section

 

This full EIA was completed by:

 

Name: Joanne Marriott

Job title: Domestic Abuse Housing Alliance Officer

Directorate:

Signature: Jo Marriott

 

Completion date:

 

Authorised by relevant Assistant Director (signature): Andrew ROWE

 

Date: 28 March 2024