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

(Form updated October 2023)

 

Homelessness and Rough Sleeping Strategy 2025/2030

 

 

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 Needs

 

Lead Officer and contact details

Kim Robertshaw, Head of Housing Needs

 

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

Sarah Wintringham, Housing Needs Service Manager

Maggie Gibson, Housing Needs Service Manager

Richard Mair, Corporate Strategy and Performance Lead (Community Development)

 

 

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


The overarching EIA has been carried out by the Housing Needs team in consultation with Strategy and Performance.

 

Legislation- Equality Duty As a local authority that provides services to the public, North Yorkshire Council has a legal responsibility to ensure that we can demonstrate having paid due regard to the need to:

·         Eliminate discrimination,

·         harassment, victimisation.

·         Advance Equality of Opportunity

 

Foster good relations for the following protected characteristics:

Age, Disability, Gender reassignment, Marriage and civil partnership, Pregnancy and maternity, Race, Religion and belief, Sex (Gender), Sexual orientation

What is prohibited?

·         Direct Discrimination

·         Indirect Discrimination

·         Harassment

·         Victimisation

·         Discrimination by association

·         Discrimination by perception

·         Pregnancy and maternity discrimination

·         Discrimination arising from disability

·         Failing to make reasonable adjustment

 

When did the due regard process start?

May 2024

 

 

 

 

 

Section 1. Please describe briefly what this EIA is about.

 

Adoption of a North Yorkshire Homelessness and Rough Sleeping Strategy 2025-30. 

 

To adopt a homelessness and rough sleeping strategy is a statutory requirement, providing an agreed strategic approach to delivering housing options and homelessness services. 

 

Under the Homelessness Act 2002, all housing authorities have a statutory duty to have in place a homelessness strategy based on a review of all forms of homelessness in their district. The strategy must be renewed at least every five years.

 

The strategy must set out the authority’s plans for the prevention of homelessness and for ensuring that sufficient accommodation and support are or will be available for people who become homeless or who are at risk of becoming so.

 

 The Homelessness and Rough sleeping strategy is the Council’s overall strategic plan. It is the public facing document expressing the Council’s vision and priorities for housing needs services over the next five years. 

 

The Strategy is also the key strategic document which sets the framework for our housing options and homelessness service. It also contains information about specific service delivery.  

 

 

 

 

Section 2. Why is this being proposed? What are the aims? What does the authority hope to achieve by it?

This will be the first Homelessness and Rough Sleeping strategy for North Yorkshire. The strategy informs of the current position and challenges for homelessness across the County. It also sets out the priorities and actions that together aim to prevent homelessness and reduce rough sleeping in line with the relevant legislation. Homelessness is not just a term for someone that is rough sleeping, but covers those that are in temporary accommodation, are at risk of losing their home, are in unsuitable accommodation or cannot afford to remain in their current home.

 

The purpose of the strategy is to inform stakeholders including elected members, officers, partners and residents about the Council’s vision for housing options and homelessness services, our key objectives and the priorities for the organisation as the strategic housing authority. 

 

The strategy identifies the priorities of the authority and the framework for delivering improvements to the services. 

 

The strategy has been drafted in the context of service demand pressures across the housing service and our main internal partners. Funding provided by central government to local authorities to deliver homelessness services has been available for many years; changes to this funding would have detrimental effects on the service provision. 

 

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

 

The Strategy provides the framework for the service, its ambitions and priorities. Adoption of the strategy will signify the council’s commitment to delivering what is set out. Action plans will be developed to improve our offer to residents and enhance our services. 

 

The service often deals with people who are with dependent children, pregnant, vulnerable due to mental health, age, physical or mental disability or other special reason Vulnerable as a result of having been a member of His Majesty’s regular naval, military or air force Vulnerable as a result of having served a custodial sentence, remanded in custody Care Leavers Victims of Domestic abuse People who have lost their home as a result of an emergency This is to ensure that the services designed to meet the statutory homeless duties are shaped to ensure all groups have access to services and are considered in our approach to preventing homelessness.

 

 

Section 4. Involvement and consultation

 

As part of the development of the strategy we relaunched the NY Homeless Forum’s both in the East and the West, with the first one in Sept 24, attended by 45 partners and agencies, workshops undertaken as part of the meetings to understand issues from our partners

·           Subsequent Homeless Forums in the East and West of the County took place in Dec, attended by around 70 local services

·           Analysis of internal and external data, including:

·                     H-CLIC

·                     Young Persons Pathway and Homechoice quarterly reports, DHP awards

·                     ONS population and house price data

·                     Rough sleeping snapshots and monthly surveys.

·           Surveys to all staff within the team for user feedback

·           One-to-one and small group discussions with a total of around 30 internal and external stakeholders – including with executive member, service Director and Assistant Director

·           Feedback on key areas for the strategy via team meetings

·           Site visits undertaken by Homeless Link (partnering charity) – all four localities

·           Client focus groups/surveys.

 

June – July 25 – consultation on the draft document 

August 25 – analysis of responses and amendments to draft document. 

 

 

 

 

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

 

Adoption of the strategy and its priorities will not have an immediate budget implication. Delivery of the action plans and individual projects will have budgetary implications which will be assessed and agreed on a case-by-case basis. The strategy gives direction to the spend of Homelessness Grants that will all be consolidated from April 2026, amount of funding for NY not disclosed to the authority until Dec 25.  

 

 

 

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

 

×

 

41% of our customers approaching for Housing Advice or Homelessness were single under 35, meaningmeaning accommodation is less affordable for this age group due to the restrictions with local housing allowance.

 

Due to the restriction on Local housing allowance. We also have 53% of the register for NYHC have a 1-bed need and 35% of tenancies commenced in the last quarter were into one beds.

 

 

The strategy has outlined how the council will continue the joint partnership with CYPS to deliver 172 units as part of the Young people’s pathway for those who are homeless or threatened with homelessness, including care leavers under 25

 

North Yorkshire has a lower proportion of young people than the national average- 

24.5% under 25 compared to 29.2% nationally. 

 

In 2021, 25% of the county’s adult population was over the age of 65. This is higher than the national percentage of 18.4%.

Disability

 

×

 

Health needs are a majority issue for most of our customers. This is explained in the strategy how we will link up services and capture information better to ensure our services and offers are appropriate for our customers needs.

 

North Yorkshire has a lower proportion (19.3%) of people with a disability or long-term limiting illness whose day-to-day activities are limited a lot- against the national average of 23.69%. 

 

In terms of population projections in North Yorkshire, between 2025 and 2047, the number of people aged 65+ will increase by 58,100 - a 34.3% rise. So we could expect an increase in the number of people with a disability going forward, although this may not be exactly in line with the rise in those aged 65+.

 

 

By recognising the needs of our residents who may be more vulnerable or have specific accessibility and adaptability requirements we will improve access to housing for these groups.

 

Consultation has taken place with Health and Adult Services and with wider Health Services to help determine wider strategic approaches, which is reflected within the strategy;

 

Sex

×

 

 

This would have no effect. Homeless priorities are focused on vulnerabilities which would mean typically females may be favoured as they would typically be the main carer for children.

 

The proportion of females is slightly higher (51%) than that of males (49%). 

 

This pattern is reflected across all localities, with the exception of Richmondshire where the large number of predominantly male military personnel have the effect of reversing the proportions. 

 

According to the DA 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 and subsequent homelessness can happen to all genders, women are particularly at higher risk. The strategy is inclusive of all genders whilst training for frontline operational staff within housing options will acknowledge that domestic abuse is a gendered issue.

 

 

Our ambitions will not have any anticipated impacts on people specifically due to them sharing this particular protected characteristic.

 

Race

×

 

 

The policy will be applied equally amongst the groups and cases dealt with by case by case basis, and so the policy will have a neutral effect on this group.

 

North Yorkshire has a much lower proportion (4.77%) of people who identify with a non-UK identity than the national average (12%). 

 

Our ambitions will not have any anticipated impacts on people specifically due to them sharing this particular protected characteristic.

 

 

Gender reassignment

×

 

 

Information from the DA 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 strategy would have no effect

 

Sexual orientation

×

 

 

This would have no effect

 

In the 2021 census 11,291 (2.2%) of residents across North Yorkshire identified themselves as Lesbian, Gay, Bisexual, or Other (LGB+). 

 

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 strategy will work with partners to address the specific needs of this community.

 

Our ambitions will not have any anticipated impacts on people specifically due to them sharing this particular protected characteristic.

 

 

Religion or belief

×

 

 

 

North Yorkshire has higher levels of Christians (55.6%) than the national average (46.2%), and lower levels of all other religions than the national average. Percentages of those with no religion or not stating their religion are broadly similar to the national average. 

 

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 and become homeless.  This could have several effects including victims being more reluctant to report or resistant to their partner being arrested.

In North Yorkshire there are some diverse communities 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 or homeless legislation. Therefore, it is important to provide cultural awareness to staff of these communities.

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

 

Our ambitions will not have any anticipated impacts on people specifically due to them sharing this particular protected characteristic. 

 

 

Pregnancy or maternity

×

 

 

In 2021 there were 5133 live births in North Yorkshire.  

 

In 2020 the conception rate per 1000 for under 18’s was 10.9. This is below the rate for England (13). 

 

In 2020/21 4.2% of deliveries in North Yorkshire were to mothers from ethnic minorities, compared to the England value of 21.6%. 

 

Our ambitions will not have any anticipated impacts on people specifically due to them sharing this particular protected characteristic. 

 

Marriage or civil partnership

×

 

 

A higher percentage of North Yorkshire’s population is married or in a civil partnership (53.7%) than the national average (46.8%) 

 

Our ambitions will not have any anticipated impacts on people specifically due to them sharing this particular protected characteristic. 

 

 

 

 

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?

 

 

 

×

 

 

The population in North Yorkshire is generally sparser than the national average (77 people per square kilometre as opposed to 434 nationally). In some parts of the county this is lower still (Ryedale 36, Richmondshire 38, Craven 48, Hambleton 69).

 

Distance travelled to access services is further than the national average. The Lower Super Output Area (LSOA), which covers the Dales ward in Ryedale, is in the 10% most deprived in England for Geographical Barriers to Services. 

 

Rurality can also mean higher costs for such things as fuel for heating. 

 

Our ambitions will make things better for people living in rural areas, addressing affordability and supply of housing in rural areas. 

 

As part of the placement of households in temporary accommodation, where possible this will be within the chosen localities, transport costs will be provided where this is not possible. All offers of temporary accommodation for households accepted as homeless need to do suitable and reasonable and subject to a review

…have a low income?

 

 

 

×

 

The proportion of households in deprivation in North Yorkshire reduced between 2011 and 2021. In 2011 52.1% of households in North Yorkshire were deprived in at least one of the four dimensions (employment, education, health and disability, housing).

 

By 2021 this had fallen to 46.7%. This 5.4 percentage point reduction in North Yorkshire compared with a 5.9 percentage point reduction across England as a whole, with the proportion of households in deprivation in North Yorkshire remaining below the national average. 

Scarborough is the only North Yorkshire district above the national average level of deprivation. 9 out of the 10 most deprived neighbourhoods in North Yorkshire in 2021 were in Scarborough district. 

 

North Yorkshire also has a number of lower super output areas within the 20% most deprived in England (23 in 2019, rising from 18 in 2010) and three LSOAs in Scarborough town are within the most deprived 1% in England. 

 

Figures for long-term unemployment in North Yorkshire (0.8%) are lower than the national average (1.9%). 

 

The percentage of children in absolute low-income families is 11.3%, compared to the England value of 15.1%. 

 

The percentage of the population who claim out of work benefits in North Yorkshire is 2.0%, compared to a Great Britain percentage of 3.7% (Nomis – ONS September 2022).  

 

Percentage of people in North Yorkshire unemployed (June 2021 – June 2022) 3% - Great Britain 3.8%. 

 

Our ambitions will make things better for those on a low income, improving partnership working, access to specialist services and access to affordable homes through NYHC as well as a Private sector project to assist those able to move into the private rented sector. 

 

…are carers (unpaid family or friend)?

 

×

 

 

Carers’ allowance claimants make up 0.98% of North Yorkshire’s population. 

 

This is lower than the average for England (1.42%) but there are variations across the county. It is likely, however, that these figures do not reflect the true number of people carrying out caring roles in the county as many do not claim allowances. 

 

Our ambitions will not have any specific impact on carers. 

 

 ….. are from the Armed Forces Community

 

 

×

 

North Yorkshire has 29,831 Armed Forces Veterans. Richmondshire has the highest proportion of Armed Forces Veterans in North Yorkshire at 9.5% (3,962), which is the third highest nationally.  

 

The proportion of veterans in Richmondshire is more than double the national average rate, which is 3.8%.  

 

Harrogate has the highest number of Armed Forces Veterans in North Yorkshire with 7,076 (5.2%). 

 

Our ambitions will not have any specific impact on those from the armed forces community and we will deliver services in line with the Armed Forces Covenant.

 

The service has highly trained housing Options officers as well as a Housing Needs champion for the Armed forces.

 

 

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

North Yorkshire wide

 

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.

 

The Strategy is the Council’s overall strategic plan.

 

 

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.

 

The proposal will not affect anyone more because of a combination of protected characteristics

 

As a service we deal with all need groups including resettlement and asylum seekers as well as current and ex armed forces personnel and their families. Throughout the strategy we discuss our actions to improving how we will work with partners on those with multiple disadvantages, which will include people with low literacy levels and health issues.

The strategy has a section on partnerships which explains how the council will strengthen these to remove barriers to access to services. Strengthening the partnerships will assist those people in hard to reach to groups can benefit from our service and any gaps in service can be reduced.

The strategy ensures the council has a plan to focus on these priority groups and how the actions over the next 5 years will be dedicated to preventing and resolving their homelessness. The policy does not have a detrimental impact on households. This has a positive impact to improve and define services for those most vulnerable.

 

 

 

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.

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.)

 

 

 

 

 

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?)

 

The associated action plans will be reviewed on a yearly basis. Potential barriers and negative impact will be recorded on a quarterly summary for this to be included in the review or sooner if deemed necessary. This will be recorded by the Housing needs management team.

This will be built into the action plan process to ensure the strategy still meets the requirements of the cohort and that appropriate accommodation is provided. Recommendations of this assessment will help shape the data gathering and how we shape our process to record data on our customers to ensure all processes are accessible and meet the needs of the client group approaching as homeless.

 

We will use service data; customer contact, complaints, North Yorkshire Home Choice applications to ensure that services are not negatively impacting on any protected characteristic. 

 

 

 

 

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

Ensure that the action plans relating to the specific service changes contributing to achieving the broad outcomes of the Strategy are appropriately assessed to identify any potential equality impacts on people with protected characteristics before specific decisions are taken. 

 

Housing Needs Service managers

Annually

 

NY Homelessness and Rough sleeping partnership, NY Homelessness Forums (East,West) Safeguarding Adult Board

Ensure that equalities information on jigsaw for the service is completed and analysed as part of data collection.

 

Housing Needs Service Managers

Ongoing

 

Reports taken from Jigsaw

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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.

 

Our ambitions in the Homelessness and Rough sleeping Strategy are for better outcomes for all North Yorkshire residents despite a tough financial climate and unprecedented service demand pressures.  

 

The anticipated impacts of our ambitions are therefore positive ones.  

 

Due regard to equalities will be paid when making decisions on actions to realise these ambitions and, where appropriate, these will be subject to full EIAs. 

 

 

 

 

Section 14. Sign off section

 

 

This full EIA was completed by: 

 

Name: Kim Robertshaw 

Job title: Head of Housing Needs 

Directorate: Community Development 

Signature: 

 

Completion date: August 2025 

 

Authorised by Assistant Director: Andrew Rowe  

Date: 26th August 2025