Update on MPA progress towards meeting the Equality Standard for Local Government

Report: 14
Date: 16 November 2006
By: Chief Executive and Clerk

Summary

The report outlines where the MPA is on the Equality Standard for Local Government (ESLG) and how it proposes to respond to changes made within ESLG. It also provides a concurrent response to the MPS’ position paper in relation to the ESLG.

A. Recommendations

That members agree:

1. The actions the MPA is taking to ‘sign off’ Levels 1 & 2;
2. The steps that the MPA is taking to meet Level 3 of the ESLG; and
3. The response to the MPS’ progress towards ESLG.

B. Supporting information

Background

1. First introduced in October 2001, the Equality Standard for Local Government (ESLG) provides a framework for ensuring that ‘a comprehensive and systematic approach’ is taken towards equalities. By working through the Standard, disadvantage associated with age, disability, faith, gender, race and sexual orientation can be identified and action taken to eliminate these barriers. The Greater London Authority (GLA) agreed that all members of the GLA family group [London Development Agency (LDA); London Fire & Emergency Planning Authority (LFEPA); Metropolitan Police Authority (MPA); Transport for London (TfL)] would work towards level 5 of the Standard. The Metropolitan Police Service were also expected to meet ESLG.

2. The ultimate purpose of the ESLG is to fully integrate equalities at the heart of an organisation’s policy-making, service delivery, employment and community engagement (‘mainstreaming’). The framework uses a continuous performance management cycle of review, assessment & consultation, action and monitoring, within which are five levels of achievement:

• Level 1: Commitment to comprehensive equality policy
• Level 2: Assessment and consultation
• Level 3: Setting equality objectives and targets
• Level 4: Information systems and monitoring against targets
• Level 5: Achieving and reviewing outcomes

3. At each level, there are four substantive areas of the Standard: Leadership and Corporate Commitment; Consultation and Community Development and Scrutiny; Service Delivery and Customer Care; and Employment and Training.

4. Within these four substantive areas, the MPA has to produce evidence of progress against a series of indicators. These indicators can be from a minimum of four to up to 12 separate activities – all of which have to have evidence of progress against each equality strand. For example, at level 2: Assessment & Consultation, there are four separate indicators under the substantive area, ‘Service Delivery and Customer Care’. In order to meet this element of the level within the Standard, the MPA has generate 24 separate pieces of evidence (the four indicators x the six equality strands) to be able to demonstrate that it had satisfied the requirements of the Equality Standard.

Changes to the ESLG and challenges for the MPA

5. It should be mentioned from the onset that the ESLG was originally designed for local government. Other public bodies such as police authorities that are not service delivery bodies primarily have difficulties in fully adapting and meeting all the elements of each standard. It should also be noted that, at the time of writing this report, the MPA is the only police authority in England & Wales striving to adopt the Standard.

6. In addition, at the onset the ESLG only considered gender, disability and race. Now it encompasses all six equality strands against which evidence has to be produced. The final challenge for the MPA is size – and in this instance, size does matter. Against the size of local authorities, the MPA is tiny; this often means that the volume and range of evidence produced against all the indicators contained within the Standard will be more challenging and labour-intensive.

7. Some of the key changes to the Equality Standard include:

• The introduction of new equality legislation in relation to age, disability and gender, has resulted in the Standard being revised to fully reflect all the equality strands
• All actions at Level 1 must now be fully compliant with existing equalities legislation
• If an organisation reaches level 4, it must demonstrate sustained improvements over two years before requesting external validation (and not one year as previously validated)
• There is now provision for Levels 1 & 2 to be externally validated
• Overall assessments will now be made at the ‘lowest common denominator’ within an organisation and not at the ‘highest common factor’
• Robust demands for the timely production and publication of Equality Impact Assessments (EIAs) – including increasing demands to publish between four to five substantive EIAs on areas of the business
• The competencies against which evidence has to be produced against the ESLG has increased from 142 to 167 as a result of all equality strands being addressed

8. For the record, only three local authorities in England & Wales have achieved Level 5: Lewisham, Tower Hamlets and High Wycombe. (Newham have recently indicated that they believe that they are at Level 5.) Within the Greater London Authority (GLA) family group, both the GLA and the London Development Agency (LDA) have indicated that they are at Level 5.

Current assessment

9. With the help of an external consultant from DIALOG and the evidence gathered to date, the MPA is currently assessed at ‘…around levels 2/3’. The reason why it cannot be more precise is that, as described earlier, this is a cyclical process and that, at any stage, a business can be moving either forwards or backwards through levels – and, in some instances, even in two opposite directions at the same time in relation to different parts of the Standard.

Key actions currently taken to sign off levels 1 & 2

10. On close analysis, the current status within the MPA is not a reflection that action has not been taken but rather that actions have not been consistently recorded and updated for evidence purposes. An 8-point action plan has been agreed with the MPA’s Senior Management Team (SMT) to sign off levels 1 & 2 by April/May 2007. This plan, included in Appendix A, will be reviewed and updated regularly. Some of the key elements of the Action Plan include:

• SMT signing off 12 Equality Impact Assessments (EIAs) and publishing them on the MPA website by December 2006
• Carrying out a Disability Audit of Dean Farrar Street by an external disability audit assessor
• Introducing a Disability Leave policy to ensure compliance with Disability Equality duties

11. An auditor from Internal Audit will assist in checking systems, processes and verifying the steps taken towards completion of these levels; this too formed a key step in the action plan.

Steps currently taken towards level 3

12 There are three key steps that have been identified as requisites to meet level 3:

1. Evidence of setting and monitoring personal and business objectives
2. The carrying out of an Equal Pay Audit; and
3. The identification of corporate group at senior and middle management to ensure and drive through the changes required

13. With regards to ii) and iii), both of these activities are underway with Human Resources (HR) assisting SMT in the former; and the Policy Officers’ Group (POG) acting as the latter, again supporting SMT. In relation to i), this is being co-led by Head of Race & Diversity Unit, in conjunction with HR.

14. In addition, the MPA has decided to innovatively approach the production of its Disability Equality Scheme in relation to the Equality Standard. Each action in its Disability Equality Scheme is linked to the ESLG; in this way, evidence gathered will assist in moving the MPA towards through levels 1 & 2 and even more quickly towards level 3.

Overseeing the MPS

15. The MPA welcomes the progress made by the MPS in relation to the Standard. However, it will be important that in order to successfully achieve level 3:

• There is a corporate approach towards the recording and completing of EIAs
• The learning gained from parts of the MPS business which may be at levels 4 or 5 (e.g. Cultural Communities Resource Unit [CCRU]) are shared widely
• That the changes brought about through the Standard not only leads to greater positive consistency in employment, service delivery and community engagement, but also dovetails with initiatives such as Morris and the MPS Modernisation Programme.

C. Race and equality impact

1. There are challenges for the MPA in signing off levels 1 and 2, and progressing towards meeting level 3 by December 2007. Recent legislative changes in relation to age, the forthcoming Disability Equality Duty (which comes into force in December 2006) and the new Gender Equality Duty (April 2007) have and will place responsibilities on the Authority to actively eliminate unlawful discrimination, ensure equality of opportunity and promote good relations across all equality strands.

2. At the core of the ESLG is the mission to ensure that equality and diversity forms an integral part of an organisation’s business planning and performance management. Considerable work has been carried out to date by the MPA towards demonstrating this fact, for example:

• in employment: the progress made in meeting and exceeding equality targets for gender and disability as acknowledged by the GLA
• in service delivery: its overseeing, scrutinising and challenging of the changes in Directorate of Professional Standards (DPS) following on from the Morris Report
• in community engagement: groundbreaking work delivered in relation to counter-terrorism such as events like ‘Together Against Terror?’

3. This is not to say that the MPA has yet ‘ticked all the boxes’; however, it is making significant steps to secure level 3 and beyond. However, in moving to the next phase, it now has to demonstrate that individual staff not only have personal objectives, but also have personal equality & diversity objectives; that these personal objectives are linked to the work plans of the respective business unit; and that the unit’s business plans directly feed into the MPA’s corporate objectives as well as committee objectives. The link between personal, business units and corporate objectives is critical to ‘mainstreaming’ equality & diversity.

D. Financial implications

1. Since November 2005, £4250.00 has been spent with a DIALOG consultant to assist the MPA verify where it is on the Standard. This cost has covered initial external assessments of where the MPA is on the Standard; a workshop with policy leads in the MPA on the function, process and amendments to the ESLG; how ESLG fits with the MPA’s Disability Equality Scheme (as well as the MPA’s proposed Generic Equality Scheme); and a series of meetings, workshops and telephone consultations with Race & Diversity Unit staff.

2. DIALOG has indicated that the cost of external assessment of the ESLG is £7000.00 per level; it is (often) undertaken by two external assessors and usually takes two days to complete. This has been done from level 3 onwards, with levels 1 and 2 self-assessed. However, with recent and forthcoming legislative changes, DIALOG are debating whether self-assessment will still be required at Levels 1 & 2 – as opposed to external verification.

3. Following discussions at SMT, it has been agreed that any assessment costs post-level 3 will be met corporately and not from R&DU’s budget.

E. Background papers

• The Equality Standard – The Employers’ Organisation For Local Government
• IDeA papers on ESLG
• Report to SMT and Policy Officers’ Group on ESLG, Generic Equality Scheme and MPA Improvement Programme
• DIALOG note to ALG (London Councils) on ESLG

F. Contact details

Report author: Laurence Gouldbourne, MPA

For more information contact:

MPA general: 020 7202 0202
Media enquiries: 020 7202 0217/18

Appendix 1

8-point plan towards signing off levels 1& 2 of the ESLG

The following is an agreed 8-point plan towards the MPA being able to formally ‘sign off’ levels 1 & 2 of the ESLG. It is not listed in order of priority; however, it does provide a basis for key activities to be met in order to secure level 3.

1. Sign off 12 outstanding EIAs by December 2006; agree to undertake four to five significant EIAs in a business year
   MPA Senior Management Team (SMT) is currently signing off a range of EIAs including HR, security and policies related to independent custody visitors (ICVs). Once completed, these EIAs will go onto the MPA website.
   The external consultant from DIALOG has recommended that the MPA conducts between four to five significant EIAs in a business year, which would go beyond initial assessments and move towards partial and full equality impact assessments; the results of these significant EIAs would be published on the MPA website. Some of these EIAs could be carried out in conjunction with the MPS; however, it would also be appropriate for the MPA to conduct such EIAs on its own business.
2. Update MPA Corporate Equality Policy, ensuring legal compliance with race, gender, age, disability, faith and sexual orientation; new and retrospective policies to be equality proofed for race, gender, disability and age to ensure legal compliance
   The Corporate Equality Policy (CEP) needs to be updated to ensure that it is legally compliant with existing and forthcoming equality legislation. It is proposed that the CEP Statement is updated early in 2007, with the CEP itself to follow during the year. Whilst all policies will be equality proofed across all equality strands, DIALOG has reminded local authorities that retrospective and future policies must be legally compliant with equalities legislation.
3. Introduce Disability Leave Policy
   In order to ensure not only legal compliance, but also best practice, MPA Human Resources are leading on producing a Disability Leave policy, supported by MPA Race & Diversity Unit.
4. Undertake Disability Audit of Dean Farrar Street and review Emergency Evacuation procedures for disability equality
   MPA SMT has agreed that a Disability Audit of the MPA’s HQ will be carried out by an external assessor who also has experience of reviewing emergency evacuation procedures within the framework of disability equality.
5. Undertake an Equal Pay Audit
   In preparation for one of the main objectives for securing external validation at level 3, SMT and representatives from PCS, with support from MPA HR, are currently undertaking this work area.
6. All staff to have at least one equality objective set and agreed; all committees to have one equality target and or objective set
   This will be one of the main cornerstones of achieving level 3 of the ESLG. Some of this work has been progressed through the MPA Improvement Programme; however, it will be important to support managers to assist and develop their staff in this area of the business.
7. Agree a central team (Policy Officers’ Group [POG]) to agree, progress and sign off areas of key activities in across levels;
   Another key development in preparation for level 3: whilst MPA SMT has overall responsibility for overseeing and managing the progress towards the levels, there has to be a team – at middle management level – that drives through the changes in the organisation. It has been agreed that this team will be the Policy Officers’ Group, which is made up of the managers leading the various team in the MPA.
8. Agree Internal Audit to internally verify where the MPA is on the ESLG
   Given the expertise already resident in the Authority, Internal Audit will be used to assess where the MPA is against levels 1 and 2. Internal Audit will also assist in building key systems and processes to ensure that the MPA can successfully achieve level 3 and beyond.

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