ILF Scotland

EQIA: TF04 - Treatment of Capital

Type of document: Equality Impact Assessments (EQIA)

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Published: June 14, 2022

Title of policy / practice / strategy / legislation:
Transition Fund Policy - TF04 - Treatment of Capital

Is this a new policy or revision to an existing policy?
Revision to Policy

Screening

Policy Aim

The aim of this policy is to increase the capital sum amount held by a recipient from £27,250 to £28,500 for eligibility to apply for a grant from the ILF Transition Fund. The proposed policy change has arisen because ILF Scotland match its capital limit for its funding with the Social Work Scotland residential care home capital limit, which has increased to £28,500. This policy change is to bring us in line with this up-to-date figure. This should be read in conjunction with the original and any previous EQIAs for TFO4.

Who will it affect?

The proposed change will affect the target group of young people aged 16 to 25 years in transition from childhood to adulthood and will be open to all protected characteristic groups provided the age eligibility criteria is met.

What might prevent the desired outcomes being achieved?

Public information and stakeholder consultation has and continues to be an integral part of this policy formulation and implementation. Person centred and equality / diversity training has been provided for key ILF Scotland staff and application and internal processes to deliver the ILF Transition Fund have involved disabled people and their representative organisations.

Stage 1: Framing

Results of Framing Exercise

ILF Scotland do not actively gather data on the statistics of young people with capital as we do not have access to this information. There is no evidence to suggest that the young people applying to the Transition Fund would consider the increase in capital sum as a barrier. Disabled people are one of the most impoverished groups in society, meaning a very small number of them would be impacted by the change in capital sum. ILF Scotland view the increase as a positive change as it allows young people accessing the Transition Fund to hold a larger capital sum.

Extent / Level of EQIA Required

The existing ILF Scotland Fund is only for disabled people. On the basis of screening for each protected characteristic against these parameters, impact will be minimal in other areas.

Stage 2: Data and Evidence Gathering, Involvement and Consultation

Include here the results of your evidence gathering, (including framing exercise), including qualitative and quantitative data and the source of that information, whether national statistics, surveys or consultations with relevant equality groups.

Characteristic: Age

Evidence gathered and strength / quality of evidence:

Source:

Data gaps identified and action taken:

Characteristic: Disability

Evidence gathered and strength / quality of evidence:

Source:

Data gaps identified and action taken:

Characteristic: Sex

Evidence gathered and strength / quality of evidence: We have specifically ensured the associated documents are de-gendered and application is not based on sex. Gender is identified in an equalities monitoring section of the application but does not influence the evaluation of applications.

Source: Co-Production group

Data gaps identified and action taken: ILF Scotland will monitor applications to the fund. If this data highlights gender specific issues, we will work co-jointly with partner organisations to assess how ILF Scotland should take appropriate action to address this.

Characteristic: Pregnancy and Maternity

Evidence gathered and strength / quality of evidence: Our policies are gender neutral and are flexible to allow for changes in circumstances.

Source: Co-Production Group

Data gaps identified and action taken: We will cross reference with gender data collected so that impact on this protected characteristic is fully assessed if identified.

Characteristic: Gender Reassignment

Evidence gathered and strength / quality of evidence: Our policies are gender neutral and are flexible to allow for changes in circumstances.

Source: Qualitative data will be captured on a voluntary basis through equality monitoring returns requested from successful recipients. We will review how we could capture the same information from all applications for future.

Data gaps identified and action taken: To inform our intelligence on gender reassignment we intend to ask successful applicants to complete an anonymous equality monitoring form when application is agreed.

Characteristic: Sexual Orientation

Evidence gathered and strength / quality of evidence: Our policies have been screened and do not discriminate in terms of sexual orientation. Eligibility is not based on sexual orientation. This information is identified in an equalities monitoring section of the application but does not influence the evaluation of applications.

Source: Co-Production group. Qualitative data will be captured on a voluntary basis through equality monitoring returns requested from successful recipients. We will review how we could capture the same information from all applications for future.

Data gaps identified and action taken: ILF Scotland Policies.

Characteristic: Race

Evidence gathered and strength / quality of evidence: Our policies have been screened and do not discriminate in terms of race. This is identified in an equalities monitoring section of the application but does not influence the evaluation of applications.

Source: Qualitative data will be captured on a voluntary basis through equality monitoring returns requested from successful recipients. We will review how we could capture the same information from all applications for future.

Data gaps identified and action taken: We are aware that there was a limited ethnic profile in the historical award fund which may be linked to the fact that very few ethnic communities access statutory services. We will ensure our application arrangements are responsive to requests from ethnic minorities, including Asylum Seekers who have Leave to Remain. This will include access to different languages and translation services if required.

Characteristic: Religion or Belief

Evidence gathered and strength / quality of evidence: Our policies and guidance allow for circumstances which require support based on cultural or religious belief. This is identified in the equalities monitoring section of the application but does not influence the evaluation of applications.

Source: Qualitative data will be captured on a voluntary basis through equality monitoring returns requested from successful recipients.

We will review how we could capture the same information from all applications for future.

Data gaps identified and action taken:

Characteristic: Marriage and Civil Partnership

(the Scottish Government does not require assessment against this protected characteristic unless the policy or practice relates to work, for example HR policies and practices - refer to Definitions of Protected Characteristics document for details).

Evidence gathered and strength / quality of evidence: This policy doesn’t base eligibility on marriage or civil partnership.

Source:

Data gaps identified and action taken:

Stage 3: Assessing the Impacts and Identifying Opportunities to Promote Equality

Having considered the data and evidence you have gathered; this section requires you to consider the potential impacts – negative and positive – that your policy might have on each of the protected characteristics. It is important to remember the duty is also a positive one – that we must explore whether the policy offers the opportunity to promote equality and / or foster good relations.

Do you think that the policy impacts on people because of their age?

Age: Eliminating unlawful discrimination, harassment and victimisation
Positive:
Negative:
None:
Reason for your decision:

Age: Advancing equality of opportunity
Positive:
Negative:
None:
Reason for your decision:

Age: Promoting good relations among and between different age groups
Positive:
Negative:
None:
Reason for your decision:

Do you think that the policy impacts disabled people?

Disability: Eliminating unlawful discrimination, harassment and victimisation
Positive:
Negative:
None:
Reason for your decision:

Disability: Advancing equality of opportunity
Positive:
Negative:
None:
Reason for your decision:

Disability: Promoting good relations among and between disabled and non-disabled people
Positive:
Negative:
None:
Reason for your decision:

Do you think that the policy impacts on men and women in different ways?

Sex: Eliminating unlawful discrimination
Positive:
Negative:
None:
Reason for your decision: The policy is gender neutral.

Sex: Advancing equality of opportunity
Positive:
Negative:
None:
Reason for your decision: The policy is gender neutral. Careful consideration will be given to ensuring public information is widely distributed to agencies supporting young disabled people with this characteristic.

Sex: Promoting good relations between men and women
Positive:
Negative:
None:
Reason for your decision: The policy is gender neutral.

Do you think that the policy impacts on women because of pregnancy and maternity?

Pregnancy and Maternity: Eliminating unlawful discrimination
Positive:
Negative:
None:
Reason for your decision: Pregnancy will not be a barrier to access if age and disability criteria are met.

Pregnancy and Maternity: Advancing equality of opportunity
Positive:
Negative:
None:
Reason for your decision: Woman with birth or childcare responsibilities will have access to the ILF Transition Fund on the same basis as other eligible applicants. Careful consideration will be given to ensuring public information is widely distributed to agencies supporting young disabled people with this characteristic.

Pregnancy and Maternity: Promoting good relations
Positive:
Negative:
None:
Reason for your decision: Individuals with parenting responsibilities will be eligible to access the ILF Transition Fund if other eligibility criteria are met thus promoting equality.

Do you think your policy impacts on transsexual people?

Gender reassignment: Eliminating unlawful discrimination
Positive:
Negative:
None:
Reason for your decision: Transgender and sexuality are not barriers to eligibility. The ILF Transition Fund will be accessible to individuals irrespective of gender, gender reassignment, sexuality where they qualify within the age and disability requirements. There will be no obligation to reveal this protected characteristic at any point in the application process. Successful applicants will be invited to complete a voluntary, anonymous equality monitoring form post successful application to enable the organisation to monitor the equality impact of the policy for future decision making.

Gender reassignment: Advancing equality of opportunity
Positive:
Negative:
None:
Reason for your decision: The application process will safeguard against potential discrimination on the basis of gender or sexuality whilst giving access to applicants with dual protected characteristics. Careful consideration will be given to ensuring public information is widely distributed to agencies supporting young disabled people with this characteristic.

Gender reassignment: Promoting good relations
Positive:
Negative:
None:
Reason for your decision: As with other protected groups who may be discriminated against, the ILF Transition Fund will seek to reduce inequality and discrimination which can cause hostilities and perceived unfairness between protected groups.

Do you think that the policy impacts on people because of their sexual orientation?

Sexual Orientation: Eliminating unlawful discrimination
Positive:
Negative:
None:
Reason for your decision: Transgender and sexuality are not barriers to eligibility. The ILF Transition Fund will be accessible to individuals irrespective of gender, gender reassignment, sexuality where they qualify within the criteria. There will be no requirement to reveal this protected characteristic at any point in the application process. Successful applicants will be invited to complete a voluntary, anonymous equality monitoring form post successful application to enable the organization to monitor the equality impact of the policy for future decision making.

Sexual Orientation: Advancing equality of opportunity
Positive:
Negative:
None:
Reason for your decision: The application process will safeguard against potential discrimination on the basis of gender or sexuality whilst giving access to applicants with dual protected characteristics. Careful consideration will be given to ensuring public information is widely distributed to agencies supporting young disabled people with this characteristic.

Sexual Orientation: Promoting good relations
Positive:
Negative:
None:
Reason for your decision: As with other protected groups who may be discriminated against, the ILF Transition Fund will seek to reduce inequality and discrimination which can cause hostilities and perceived unfairness between protected groups.

Do you think the policy impacts on people on the grounds of their race?

Race: Eliminating unlawful discrimination
Positive:
Negative:
None:
Reason for your decision: The policy does not base eligibility criteria on race.

Race: Advancing equality of opportunity
Positive:
Negative:
None:
Reason for your decision: The application process will safeguard against potential discrimination on the basis of race whilst giving access to applicants with dual protected characteristics. Careful consideration will be given to ensuring public information is widely distributed to agencies supporting young disabled people with this characteristic. Information on the ILF Transition Fund and applications to the fund can be made available, on request, in a range of languages.

Race: Promoting good race relations
Positive:
Negative:
None:
Reason for your decision: As with other protected groups who may be discriminated against, the ILF Transition Fund will seek to reduce inequality and discrimination which can cause hostilities and perceived unfairness between protected groups.

Do you think the policy impacts on people because of their religion or belief?

Religion or belief: Eliminating unlawful discrimination
Positive:
Negative:
None:
Reason for your decision: The policy does not base eligibility criteria on religion or belief.

Religion or belief: Advancing equality of opportunity
Positive:
Negative:
None:
Reason for your decision: The policy does not base eligibility criteria on religion or belief. The application process will safeguard against potential discrimination on the basis of religion or belief whilst giving access to applicants with dual protected characteristics.

Religion or belief: Promoting good relations
Positive:
Negative:
None:
Reason for your decision: The policy does not base eligibility criteria on religion or belief. As with other protected groups who may be discriminated against, the ILF Transition Fund will seek to reduce inequality and discrimination which can cause hostilities and perceived unfairness between protected groups.

Do you think the policy impacts on people because of their marriage or civil partnership?

Marriage and Civil Partnership: Eliminating unlawful discrimination
Positive:
Negative:
None:
Reason for your decision: The policy does not base eligibility criteria on marital status or civil partnership. As with other protected groups who may be discriminated against, the ILF Transition Fund will seek to reduce inequality and discrimination which can cause hostilities and perceived unfairness between protected groups.

Stage 4: Decision Making and Monitoring

Identifying and establishing any required mitigating action

If, following the impact analysis, you think you have identified any unlawful discrimination – direct or indirect - you must consider and set out what action will be undertaken to mitigate the negative impact.

Have positive or negative impacts been identified for any of the equality groups?

Is the policy directly or indirectly discriminatory under the Equality Act 2010?

If the policy is indirectly discriminatory, how is it justified under the relevant legislation?

If not justified, what mitigating action will be undertaken?

Describing how Equality Impact Analysis has shaped the policy making process

Monitoring and Review

Stage 5: Authorisation of EQIA

Please confirm that:

This Equality Impact Assessment has informed the development of this policy:

Yes

Opportunities to promote equality in respect of age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex and sexual orientation have been considered, i.e.:

  • eliminating unlawful discrimination, harassment, victimisation
  • removing or minimising any barriers and / or disadvantages
  • taking steps which assist with promoting equality and meeting people’s different needs
  • encouraging participation (e.g. in public life)
  • fostering good relations, tackling prejudice and promoting understanding

Yes

If the Marriage and Civil Partnership protected characteristic applies to this policy, the Equality Impact Assessment has also assessed against the duty to eliminate unlawful discrimination, harassment and victimisation in respect of this protected characteristic.

Not applicable

Declaration

I am satisfied with the Equality Impact Assessment that has been undertaken for the revision to Policy TF04 - Treatment of Capital.

Name: Linda Scott
Position: Director of Policy, Improvement & Engagement
Authorisation Date: 31 March 2021

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