Equality Impact Assessment...Equality Impact Assessment Revised Version 4 Nov 2011 Page 5 of 34 Benefit Group who benefit 1. Supports financial inclusion initiatives. Gives greater

Revised Version 4 Nov 2011 Page 1 of 34

Equality Impact Assessment Project or Service Template

Name of the proposal, project or service

Direct Payments – Prepaid Cards

File ref: Issue No:

Date of Issue: 13/02/13 Review date: 18/04/13

Contents

Part 1 – The Public Sector Equality Duty and Equality Impact Assessments (EIA)1

Part 2 – Aims and implementation of the proposal, project or service .................... 4

Part 3 – Methodology, consultation, data and research used to determine impact on protected characteristics.................................................................................... 7

Part 4 – Assessment of impact ............................................................................... 9

Part 5 – Conclusions and recommendations for decision makers ........................ 27

Part 6 – Equality impact assessment action plan.................................................. 30

How to use this form

Press F11 to jump from field to field in the form. There are comments on some questions which you can view by pressing the show/hide pilcrow icon in the tool bar of Word. Some of you may use this to show paragraph and other punctuation marks: You can delete the comments as you would for normal text, but they will not show up if you print out the form.

To complete – press F11 to jump from field to field

Page 1 of 34

Part 1 – The Public Sector Equality Duty and Equali ty Impact Assessments (EIA)

1.1 The Council must have due regard to its Public Sector Equality Duty when making all decisions at member and officer level. An EIA is the best method by which the Council can determine the impact of a proposal on equalities, particularly for major decisions. However, the level of analysis should be proportionate to the relevance of the duty to the service or decision. 1.2 This is one of two forms that the County Counci l uses for Equality Impact Assessments, both of which are available on the int ranet. This form is designed for any proposal, project or service. The other for m looks at services or projects. 1.3 The Public Sector Equality Duty (PSED) The public sector duty is set out at Section 149 of the Equality Act 2010. It requires the Council, when exercising its functions, to have “due regard� to the need to

• eliminate direct and indirect discrimination, harassment and victimisation and other conduct prohibited under the Act,

• advance equality of opportunity and foster good relations between those who

share a “protected characteristic� and those who do not share that protected characteristic (see below for “protected characteristics”

• foster good relations between persons who share a relevant protected

characteristic and persons who do not share it These are sometimes called equality aims. 1.4 A “protected characteristic � is defined in the Act as:

• age; • disability; • gender reassignment; • pregnancy and maternity; • race (including ethnic or national origins, colour or nationality) • religion or belief; • sex; • sexual orientation.

Marriage and civil partnership are also a protected characteristic for the purposes of the duty to eliminate discrimination. The previous public sector equalities duties only covered race, disability and gender. 1.5 East Sussex County Council also considers the f ollowing additional groups/factors when carry out analysis:

• Carers – A carer spends a significant proportion of their life providing unpaid support to family or potentially friends. This could be caring for a relative, partner or friend who is ill, frail, disabled or has mental health or substance misuse problems. [Carers at the Heart of 21stCentury Families and Communities, 2008]

• Literacy/Numeracy Skills

Equality Impact Assessment Revised Version 4 Nov 2011

Page 2 of 34

• Part time workers • Rurality

1.6 Advancing equality (the second of the equality aims) involves:

• Removing or minimising disadvantages suffered by people due to their protected characteristic.

• Taking steps to meet the needs of people from protected groups where these are

different from the needs of other people including steps to take account of disabled people’s disabilities.

• Encouraging people from protected groups to participate in public life or in other

activities where their participation in disproportionately low.

NB Please note that, for disabled persons, the Council must have regard to the possible need for steps that amount to positive discrimination, to “level the playing field” with non-disabled persons, e.g. in accessing services through dedicated car parking spaces. 1.6 Guidance on Compliance with The Public Sector E quality Duty (PSED) for officers and decision makers: 1.6.1 To comply with the duty, the Council must have “due regard” to the three equality aims set out above. This means the PSED must be considered as a factor to consider alongside other relevant factors such as budgetary, economic and practical factors. 1.6.2 What regard is “due” in any given case will depend on the circumstances. A proposal which, if implemented, would have particularly negative or widespread effects on (say) women, or the elderly, or people of a particular ethnic group would require officers and members to give considerable regard to the equalities aims. A proposal which had limited differential or discriminatory effect will probably require less regard. 1.6.3 Some key points to note :

• The duty is regarded by the Courts as being very important. • Officers and members must be aware of the duty and give it conscious

consideration: e.g. by considering open-mindedly the EIA and its findings when making a decision. When members are taking a decision,this duty can’t be delegated by the members, e.g. to an officer.

• EIAs must be evidence based. • There must be an assessment of the practical impact of decisions on equalities,

measures to avoid or mitigate negative impact and their effectiveness. • There must be compliance with the duty when proposals are being formulated by

officers and by members in taking decisions: the Council can’t rely on an EIA produced after the decision is made.

• The duty is ongoing: EIA’s should be developed over time and there should be evidence of monitoring impact after the decision.

• The duty is not, however, to achieve the three equality aims but to consider them – the duty does not stop tough decisions sometimes being made.


Page 3 of 34

• The decision maker may take into account other countervailing (i.e. opposing) factors that may objectively justify taking a decision which has negative impact on equalities (for instance, cost factors)

1.6.4 In addition to the Act, the Council is required to comply with any statutory Code of Practice issued by the Equality and Human Rights Commission. New Codes of Practice under the new Act have yet to be published. However, Codes of Practice issued under the previous legislation remain relevant and the Equality and Human Rights Commission has also published guidance on the new public sector equality duty.


Page 4 of 34

Part 2 – Aims and implementation of the proposal, p roject or service

2.1 What is being assessed?

a) Proposal or name of the project or service.

Implementation of Prepaid Cards as the method of providing Direct Payments in Adult Social Care

b) What is the main purpose or aims of proposal, pr oject or service?

1. To remove the need for a client to open their own bank account to manage a direct payment.

2. To remove the need for individual monitoring of paper based returns forms,

moving to a more automated and focussed form of monitoring direct payments. 3. To provide ESCC/ASC with a secure and efficient way of making direct payments

to clients and carers. 4. Greater control and flexibility over the amount of money that is paid into client

accounts each month. 5. To enable ESCC/ASC Direct Payments Support team, to put in place a robust risk

management model as part of the simplified reconciliation process for Direct Payments.

6. To enable a light touch monitoring approach, reviewing activity that is outside of

pre set parameters which will highlight areas to be reviewed. 7. To create reporting that will enable intelligent checking of accounts and

transactions as and when required. 8. The ability for ESCC/ASC to view detailed statements and management

information online as if a bank account. 9. The ability for ESCC/ASC to block spending in certain provider groups that are not

inline with any care plan such as online gambling websites and off-licences. Although this is not an aim and unlikely to be used other than blocking cash it is still a desirable function that can be used. Cash will be blocked but will be able to be unblocked should a client need cash. This will be considered on a case by case basis.

c) Manager(s) and section or service responsible fo r completing the assessment

Frood Radford and Laura Salter, Adult Social Care, Direct Payments

2.2 Who is affected by the proposal, project or ser vice? Who is it intended to benefit and how?


Page 5 of 34

Benefit Group who benefit

1. Supports financial inclusion initiatives. Gives greater choice, control and empowerment to clients, in line with Self Directed Support/Personal Budget principle.

Clients

2. Saving from reduced use of managed accounts. Clients and ASC

3. Ability to set up an additional card for a person nominated by the cardholder such as a spouse. Clients

4. Removes the need for the client to set up a bank account Clients

5. Removes the need for the client to send in 4 weekly receipts and duplicate information sent in. Clients

6. Allows the user to pay for goods/services using a debit style card which most clients are already familiar with. Clients

7. Purchases can be made over the phone, online or in person. Clients

8. Client & Carer – have access to online statements for easy record keeping. Clients and DP Support team

9. Tool to support the take up of direct payments. ASC

10. Improved and consistent reconciliation process as there would be no delay in processing returns. Instead there would be online real-time access to spending information.

DP Support Team

11. Online monitoring would align us with the audit requirement to review the current monitoring process and put a robust system in place.

ASC - Audit

12. Improved security of payment resulting in reduced fraud. ASC – Audit and Finance

13. Tightened control through detailed reporting. ASC – Audit and Finance

14. Savings generated with virtually paperless returns i.e. no postage (prepaid envelopes) required. ASC

15. Due to a monitoring process with specific alerts set for all accounts rather than checking each account individually, if Direct Payments increase this will have a minimal or no affect on the number of ESCC staff working on monitoring.

ASC

16. Clear view of account balances to evaluate funds held for budgets/accounting purposes. Clients and DP Support Team

17. Allows providers to receive payment for goods/services using electronic/card payment methods such as Visa/MasterCard that is a recognised industry standard via the internet, telephone or chip and pin in person.

Care Providers

18. Payments can be made in real time; as a result providers will receive payment more quickly. Care Providers

19. Empowering for clients as ESCC are able to take a hands off approach due to the reduction in paper returns requested on a regular basis.

Clients

20. Provides a much more effective way of monitoring what money is spent on allowing information to be kept electronically.

DP Support Team

21. Easier to compare spend across groups ASC

22. Reporting can be created that will highlight issues rather than them having to be found amongst other information.

DP Support Team

23. More focus can be spent on under spend, reports can highlight this and staff will have more time to review these cases.

Clients and ASC

24. Prepaid card accounts belong to ESCC, as a result to claw back money ESCC will not have to request permission from the client and this process will be much quicker.

ASC

25. Prepaid Cards provide clients with choice and control but ensure ESCC has an effective monitoring system in place that does not hinder client’s experience of Direct Payments

Clients and ASC

26. Monitoring of Prepaid Card payments will automate the check for client contribution on a regular basis to ensure this is being paid into the account from reports and spot checks of live statements.

Clients and DP Support Team


Page 6 of 34

2.3 How is, or will, the proposal, project or servi ce be put into practice and who is, or will be, responsible for it?

Frood Radford and Laura Salter will manage the project overseen by the project board. This will include client engagement regarding the project, the appointment of the Prepaid Card supplier and the creation of all documentation/training associate with the pilot and full implementation stages of the project.

2.4 Are there any partners involved? E.g. NHS Trust , voluntary/community organisations, the private sector? If yes, how are partners involved?

A4e who provide managed accounts will be informed but it will not change the way they manage the accounts they have unless decided at a later stage.

2.5 Is this proposal, project or service affected b y legislation, legislative change, service review or strategic planning activi ty?

No

2.6 How do people access or how are people referred to your proposal, project or service? Please explain fully.

Practitioners inform clients when applicable that they are entitled to receive their personal budget as a direct payment with the costs and options of managing these, if the client then decides to self manage, this would then be provided in the form of a Prepaid Card.

2.7 If there is a referral method how are people as sessed to use the proposal, project or service? Please explain fully.

At the support planning for personal budgets stage of the self-directed support pathway, clients who have eligible social care needs and are entitled to support, will be informed by a practitioner of the options to meet their care requirements. If they select direct payments and are willing and able to self manage the account, they will be issued with a prepaid card as the method of receiving the funds.

2.8 How, when and where is your proposal, project o r service provided? Please explain fully.

Once a client decides to have a self managed Direct Payment as the method of receiving their personal budget, a card will be sent to them in the post with information on how to use it. The client can then call the customer service centre and activate the card; once this is done they can start using the funds on the card.

The Direct Payments are paid on a weekly cycle. Funds will be loaded onto the card and accessed by the client in order to pay for the services as and when they require it according to their care plan.

Clients will be able to view and manage the funds on the prepaid card online and over the telephone in a similar way to online banking.


Page 7 of 34

Part 3 – Methodology, consultation, data and resear ch used to determine impact on protected characteristics.

3.1 List all examples of quantitative and qualitati ve data or any consultation information available that will enable the impact a ssessment to be undertaken.

Types of evidence identified as relevant have X marked against them

Employee Monitoring Data Staff Surveys

x Service User Data x Contract/Supplier Monitoring Data

x Recent Local Consultations Data from other agencies, e.g. Police, Health, Fire and Rescue Services, third sector

x Complaints Risk Assessments

x Service User Surveys x Research Findings

x Census Data x East Sussex Demographics

Previous Equality Impact Assessments

x National Reports

x Other organisations Equality Impact Assessments

Any other evidence?

3.2 Evidence of complaints against the proposal, pr oject or service on grounds of discrimination.

No evidence

3.3 If you carried out any consultation or rese arch on the proposal, project or service explain what consultation has been carried out.

Membership of The National Prepaid Card Steering Group which includes suppliers and authorities using or thinking about using prepaid cards.

Meetings with Kent and Hounslow to discuss PPC experiences as well as Merton and Brent through the Steering Group.

Consultation with DP Peer group at event in April 2013 and request for Pilot Volunteers

Presentations from suppliers

3.4 What does the consultation, research and/or dat a indicate about the positive or negative impact of the proposal, project or serv ice?

The feedback from members of The National Prepaid Card Steering Group who have implemented the cards, suggests that the cards promote social inclusion, enabling those who would not normally have access to a bank account the ability


Page 8 of 34

to use the cards which work in a very similar way. They also indicated clients felt it gave them more control over the money as they didn’t have to record every payment and could see what the balance was at any time. The main positive impact given by those who have already implemented the cards is the level of support in place for clients online and over the telephone, as well as information sent out with the card. As long as this information is accessible to all clients in several formats the Prepaid Card Project will have a positive impact on clients. Direct Payment clients who attended the Peer Support Event provided feedback on a presentation introducing them to Prepaid Cards. The response was mainly positive with some signing up to be part of the pilot. However there was some concern regarding the use of the internet. Although it is not essential for clients use the internet to make payments using the Prepaid Card this didn’t seem clear. This supports the information provided by other authorities which suggests the information sent out to clients must be clear on how to use the card and that there are a number of ways to use it not just online.


Page 9 of 34

Number of clients receiving a direct payment by age

Unknown0%

85 and over20%

75 - 8416% 65 - 74

10%

18 - 6454%

Part 4 – Assessment of impact

4.1 Age: Testing of disproportionate, negative, neutral or p ositive impact.

a) How is this protected characteristic reflected i n the County/District/Borough?

Percentage of population receiving a direct payment by age

Number of people receiving a direct payment

Population Percentage of population receiving a

direct payment

18 - 64 1105 302202 0.4% 65 - 74 215 59421 0.4% 75 - 84 327 41279 0.8% 85 and over 417 20022 2.1% Total 2064 422924 0.5%

b) How is this protected characteristic reflected i n the population of those impacted by the proposal, project or service?

Number of people receiving a direct payment by age

Number of older people (65 and over) receiving a direct payment by primary client type

Physical /Sensory /Frailty 840 Learning Disability 3 Mental Health 100 Substance Misuse 0 Other vulnerable person 12 Unknown 4


Page 10 of 34

Number of older people receiving a direct payment b y primary client type

Other vulnerable person

1%Unknown

0%

Physical /Sensory /Frailty89%

Learning Disability0%

Mental Health10%

Substance Misuse0%

c) Will people with the protected characteristic be more affected by the proposal, project or service than those in the gene ral population who do not share that protected characteristic?

Possibly, yes

d) What is the proposal, project or service’s impac t on different ages/age groups?

Although there is a higher percentage of the 85 and over population who receive a direct payment, 54% of Direct Payments are made to those in the 18-64 age group.

The 18-54 age group choose or are offered Direct Payments as the method of receiving their personal budget more frequently than those in any other age group.

e) What actions are to/or will be taken to avoid an y negative impact or to better advance equality?

In order to avoid negative impact there are a number of actions that will be taken:

1) Client Engagement

Throughout the pilot stage clients of all age groups will be asked to provide feedback on their experience of using the prepaid cards, included will be questions regarding accessibility of information and how the cards are to use.

2) Client choice

Prepaid cards will only replace the bank accounts required for those who are self managing, if a client does not want to use the prepaid card they still have the option to have a managed account.

3) Telephone and online support

Support to make payments using the card will be available to clients over the telephone or online, currently this service is not available, once funds reach a clients account they need to make payments as they would from any bank account.


Page 11 of 34

4) Reduced amount of paper returns

Clients are currently expected to send return forms in to the ESCC Direct Payments monitoring team which consist of receipts, bank statements and forms that list the payments made in that four week period. The prepaid cards will remove this paperwork as the transactions are recorded online each time the card is used and can be accessed by the Direct Payments monitoring team at any time.

5) Operational training

When training operational staff information will be included to Direct Payments are offered to all clients regardless of age and that they do not need to use the internet if they don’t want to but can use the telephone to manage their Prepaid Card account.

6) Availability of information

Information for all clients will be widely available, in addition to online, telephone information and leaflets from operational staff, the information sent out with the cards will be available in a number of formats.

7) Prepaid Card accounts

The Prepaid Card Accounts work in a similar way to bank accounts, for clients who have bank accounts this will be a similar experience and as a result easier for them to use.

f) Provide details of the mitigation.

Clarity in any communications provided with information available in different formats for clients.

Effective training to ensure practitioners are clear how the cards work in order to relay the correct information to clients clearly.

g) How will any mitigation measures be monitored?

Monitoring regular feedback from clients throughout the pilot which will be conducted on a regular basis. Improvements based on this feedback will then be implemented and measured from further feedback refining the processes and communications.

Information from customer service provider regarding the type of queries clients have and if there is a pattern in questions asked. For example if clients frequently don’t understand how to activate the card when they receive the letter with instructions on this would need to be reviewed. Regular reviews will be set up throughout the pilot with the supplier to discuss this with any actions delegated to the relevant teams to make amendments accordingly

4.2 Disability: Testing of disproportionate, negati ve, neutral or positive impact.

a) How is this protected characteristic reflected i n the County /District/Borough?

Formatted: Bullets and

Numbering

Formatted: Bullets andNumbering


Page 12 of 34

The 2001 Census data showed 88,983 people who describe themselves as living with a limiting long-term illness (all ages) in East Sussex – approximately 20% of the population at that time. In February 2012 there were 25,080 people (all ages) claiming Disability Living Allowance in East Sussex (source: Dept for Work and Pensions, Longitudinal Study, Feb 2012, NOMIS).

Note: new figures from the 2011 census will be avai lable from November 2012 onwards.

Disability Living Allowance claimants by age group in February 2012

Time period

Feb-12

Broad age

Geography

Total Percent aged under 16 Percent aged 16-59 Percent aged 60 and over

Great Britain 3,267,910 10.5 50.1 39.4

South East 331,800 14.1 53.5 32.4

East Sussex 25,080 11.2 53.5 35.4

Source: Department for Work and Pensions, Longitudinal Study, NOMIS

Projected limiting long-term illness by age group, 2010-2026

Measure

Number Percent of total population

Age group

Geography

Year

All people 0-17 18-64 65+ All people 0-17 18-64 65+

2010 105,047 4,755 43,646 56,647 20.4 4.6 15.0 46.8

East Sussex

2026 124,992 4,352 42,392 78,248 23.9 4.7 15.9 47.6

Source: ESCC projections, November 2011


Page 13 of 34

Projected disability by age group, 2010-2026

Measure

Number Percent of total population

Age group

Geography

Year

All people 10-17 18-64 65+ All people 10-17 18-64 65+

2010 85,428 1,952 34,041 49,435 16.6 3.9 11.7 40.9

East Sussex

2026 103,415 1,826 33,202 68,386 19.7 3.9 12.5 41.6

Source: ESCC projections, November 2011Employment and Support Allowance and Incapacity Benefit claimants in February 2012

b) How is this protected characteristic reflected i n the reflected in the population of those impacted by the proposal, proje ct or service?

Number of people receiving a Direct Payment by disa bility

Number of people % of people Learning Disability 215 9 Physical Disability 454 19 Sensory needs / impairment (hearing &/or sight)

106

4 Mental Health condition 343 14 Long-term illness or health condition

612 26

Other disability / impairment 64 3 Prefer not to say 6 0 No disability / impairment 10 0 Not yet obtained 562 24 Total 2372 100

Please note: People can have multiple disabilities, and therefore will be reflected more than once in the figures above.


Yes, specifically those with visual impairment, learning disability and mental health (dementia)


Page 14 of 34

d) What is the proposal, project or service’s impac t on people who have a disability?

Having a Prepaid Card will stop clients going through the process of setting up a bank account and sending back forms with receipts, as a result it should reduce any confusion caused by completing paperwork that is essential with bank accounts in the current process.

Most of the information provided with the Prepaid Card will be via written text in letters, online or information sent with the prepaid card, this may cause problems for those who have visual impairments.

Transactions are automatically recorded; this will assist those with memory problems as payments no longer need to be written down and can be accessed by clients online or over the phone.

e) What actions are to/ or will be taken to avoid a ny negative impact or to better advance equality?

There will be consultation with clients at a peer group event and a pilot phase run where any impact can be reviewed.

Discussions with the LD Commissioning team regarding all information that is sent out to clients to ensure all information is accessible.

The supplier who provides the card will be aware that all elements of activating and using the card must be accessible over the phone and have text relay and minicom facilities.

f) Provide details of any mitigation.

The LD Commissioning team will produce easy to read guides available at all stages of the process where communication is sent out. This will also be compatible with screen readers and in large print when required.

Clients will also have access to the customer service telephone line provided by the card management supplier; they will be able to go through any account information including statements and payments with clients over the phone.

How will any mitigation measures be monitored?

Feedback will be obtained from clients at the pilot stage via a two stage questionnaire. Any issues that arise from this will be followed up directly with the client and/or changes will be made to the process or information accordingly.


Page 15 of 34

4.3 Ethnicity: Testing of disproportionate, negati ve, neutral or positive impact. a) How is this protected characteristic reflected i n the County

/District/Borough?

The overall population of East Sussex is 527,209 (2011Census data) and is projected to continue increasing over the next few years. The population aged 65+ (males) and 60+ (females) by ethnic group for East Sussex is shown in the table in Section 4.1above, page 12. 2011 census figures will update this picture. Currently accepted projections, below demonstrate an increase of ethnic diversity in the area to 10.5% overall. Increases are particularly in the ‘White other’ and ‘mixed’ categories reflecting East European and other white groups migration and other societal changes. Largest overall minority populations are ‘White other’ and ‘Asian and Asian British’

Ethnic groups White: British BME

England 82.8 17.2 South East 85.7 14.3 East Sussex 89.5 10.5 Eastbourne 87.6 12.6 Hastings 87.0 13.0 Lewes 90.6 9.4 Rother 90.9 9.3 Wealden 90.8 9.2

Ethnic groups

White: Irish

White: Other White All Mixed

All Asian or Asian British

All Black or Black British

All Chinese or Other Ethnic Group

England 1.1 3.6 1.8 6.1 2.9 1.6 South East 1.0 4.0 1.7 4.2 1.9 1.5

East Sussex 0.9 3.2 1.4 2.3 1.6 1.1

Eastbourne 1.0 3.9 1.6 3.1 1.5 1.5 Hastings 0.9 3.3 2.1 2.2 3.5 1.0

Lewes 0.9 3.2 1.3 2.0 0.9 1.0 Rother 0.9 2.5 1.3 2.4 1.5 0.8

Wealden 0.8 3.1 1.3 2.0 1.0 1.0 Ethnic group experimental statistics, 2001-2009 – d istricts

Ethnic groups All people All White White: Irish

White: Other White All Mixed

All Asian or Asian British

All Black or Black British

All Chinese or Other Ethnic Group

Geography England 51809700 45313200 558100 1861800 956700 3166800 1521400 851600 South East 8435700 7650900 85100 334700 144900 357000 158100 124800 East Sussex 512100 479200 4600 16300 7400 11800 8300 5400 Eastbourne 96400 89200 1000 3800 1500 3000 1400 1400 Hastings 86900 79300 800 2900 1800 1900 3000 900 Lewes 96400 91300 900 3100 1300 1900 900 1000 Rother 89200 84100 800 2200 1200 2100 1300 700 Wealden 143100 135400 1100 4400 1800 2900 1500 1400


Page 16 of 34

Number of clients from a BME background receiving a service between January and December, by ethnicity

W & Blck African; 9; 1%

Any oth Mix Bkgrd; 53; 6%

W & Blck Caribbean; 18; 2%

Caribbean; 25; 3%

Any oth black bkgrd; 27; 3%

African; 22; 2%

White & Asian; 19; 2%

Traveller; 4; 0%

Irish; 149; 16%

Gypsy / Romany; 13; 1%

Any other white Bckgrd; 432; 47%

Any oth Asian bkdrd; 31; 3%

Bangladeshi; 14; 2%Other Ethnic

Group; 48; 5%Chinese; 18; 2%

Indian; 29; 3%


Number of people receiving a service by ethnicity

Chinese 18 Other Ethnic Group 48 Any oth Asian bkdrd 31 Bangladeshi 14 Indian 29 Pakistani 3 African 22 Any oth black bkgrd 27 Caribbean 25 Any oth Mix Bkgrd 53 W & Blck African 9 W & Blck Caribbean 18 White & Asian 19 Any other white Bckgrd 432 Gypsy / Romany 13 Irish 149 Traveller 4


Page 17 of 34

Number of people receiving a Direct Payment by pref erred language

Number of People % of people Arabic 1 0.0 British Sign Language 6 0.3 Cantonese 2 0.1 Dari 2 0.1 English 1232 59.7 Farsi 1 0.0 Greek 1 0.0 Hindi 1 0.0 Italian 2 0.1 Other language 12 0.6 Portuguese 3 0.1 Not yet obtained 802 38.8 Total 2065 100.0


Potentially, yes

d) What is the proposal, project or service’s impac t on those who are from different ethnic backgrounds?

There could be barriers with regard to literacy levels and English not being a first language.

As clients need to use the Prepaid Card in order to obtain funds for care they may have difficulty understanding how to use the card as a result of the documentation provided.

However as the card is very similar to using a normal bank account, in many cases it will be easier for clients to administer than the high level of paperwork that is in place with the current process.


There will be consultation with clients at a peer group event and a pilot phase run where any impact can be reviewed.

Information will be made available to everyone in an easy to read format and the process of using the cards being made simple and clear.


All customer service, internet information and guides sent to clients will be in plain English.


Page 18 of 34

During the supplier selection process part of the selection criteria is to ensure customer service agents are able and willing to take the time a client needs to explain how the card works.

Translation of any materials sent out will be available as part of existing Adult Social Care policy in East Sussex County Council.


Feedback will be obtained from clients at the pilot stage via a two stage questionnaire. Any issues that arise from this will be followed up directly with the client and/or changes will be made to the process or information accordingly.

To ensure we receive feedback from clients under all protected characteristics, we will review the responses we have received after six months to see if any clients with protected characteristics have not provided feedback. If any gaps arise existing Direct Payment clients under that characteristic will be approached to offer insight.


Page 19 of 34

4.4 Gender/Transgender: Testing of disproportionate , negative, neutral or positive impact

a) How is this protected characteristic target grou p reflected in the County/District/Borough?

Data from the 2011 Census shows the population of East Sussex to be 527,209, broken down into the following gender and age groupings:

Total 18+ 18-64 65+ 18-64

% 65+ %

Female EAST SUSSEX 273,142 222,604 154,510 68,094 69.4 30.6

Male EAST SUSSEX 254,067 200,320 147,692 52,628 73.7 26.3

All people EAST SUSSEX 527,209 422,924 302,202 120,722 71.5 28.5 Source: ONS Mid Year Population Estimates 2011 (bas ed on Census) released on 25 th September by ONS Gender Identity: Transgender men and women are reluctant to ‘come out’ to policy makers and researchers, seeing little benefit in doing so and fearing discrimination and harassment. In addition, sources such as the census have not collected gender identity data to date. In an attempt to gather data on numbers of transgender people in East Sussex, and better understand their needs to ensure an appropriate service response for this group, data from 254 “About You” forms were analysed in Quarter 2, as part of the Listening To You satisfaction questionnaires. The questionnaires were sent to a random sample of service users who had had the provision of OT equipment or sensory equipment / service in the 3 last months; people who had a Direct Payment put in place or reviewed in the last 3 months; and carers. The responses received showed:

• 1% of respondents stated they were transgender • 5% of respondents said they preferred not to say, • 94% of respondents stated they were not transgender.

(Source: ASC Equalities Data Set, January 2012)



Page 20 of 34

Number of people receiving a Direct Payment by gend er

Female 1246 Male 819

Percentage of population receiving a direct payment by gender



direct payment

Female 1246 222604 0.6% Male 819 200320 0.4% Total 2065 422924 0.5%


The use and process of using a Prepaid will not have an impact, however information provided on the card may have an impact on transgender clients with the use of title which is printed on the card and can be seen.

d) What is the proposal, project or service’s impac t on different genders?

The title printed on the card may have a negative impact on anyone who is going through a transition phase and does or simply does not want this information shown.

e) What actions are to/ or will be taken to avoid a ny negative impact or to better advance equality?

Suppliers will be requested to not print title on the card but only use the name of the client.

Number of clients receiving a direct payment by gen der

Female60%Male

40%


Page 21 of 34


See above


The selected supplier will be requested to send samples of the final cards to be used that can be checked to ensure the title is not printed on the card.


Page 22 of 34

4.5 Marital Status/Civil Partnership: Testing of di sproportionate, negative,

neutral or positive impact.

Marital Status/Civil Partnership has been considered and is not applicable to the Prepaid Card project

4.6 Pregnancy and maternity: Testing of disproporti onate, negative, neutral or positive impact.

Pregnancy and maternity has been considered and is not applicable to the Prepaid Card project

4.7 Religion, Belief: Testing of disproportionate, negative, neutral or positive impact.

Religion and belief has been considered and is not applicable to the Prepaid Card project

4.7 Sexual Orientation - Gay, Lesbian, Bisexual and Heterosexual: Testing of disproportionate, negative, neutral or positive imp act.

Sexual orientation Gay, Lesbian, Bisexual and Heterosexual has been considered and is not applicable to the Prepaid Card project


Page 23 of 34

4.9 Other: Additional groups/factors that may exper ience impacts - testing of disproportionate, negative, neutral or positive im pact.

• Rural population

• Carers

a) How are these groups/factors reflected in the Co unty/District/ Borough?

Rural population

District Rural Population

% of Total Population

Urban Population

% of Total Population

Eastbourne 0 0 92,057 100

Hastings 0 0 84,598 100

Lewes 21,820 23.4 71,503 76.6

Rother 45,453 53.1 40,277 46.9

Wealden 69,745 49.5 71,113 50.5

East Sussex 137,108 27.6 359,548 72.4

South East Region 2009 by age

Region Area

classification 60 - 64 years

65 - 69 years

70 - 74 years

75 - 79 years

80 - 84 years

85 and over

60 and over

South East Predominantly rural 44,700 12,000 6,000 4,500 6,100 10,700 84,000

South East Predominantly urban 57,000 6,400 -1,100 -500 5,300 14,100 81,200

South East Significant rural 29,300 8,200 4,800 3,700 4,000 7,100 57,100

Commission for Rural Economies – regional extracts (2009)


Page 24 of 34

Carers

b) How is this group/factor reflected in the popula tion of those impacted by the proposal, project or service?

Percentage of population receiving a Carers Grant b y age



direct payment

18 - 64 1333 302202 0.4% 65 - 74 578 59421 1.0% 75 - 84 433 41279 1.0% 85 and over 145 20022 0.7% Total 2489 422924 0.6%

c) Will people within these groups or affected by t hese factors be more affected by the proposal, project or service than t hose in the general population who are not in those groups or affected by these fa ctors?

Yes, potentially

d) What is the proposal, project or service’s impac t on the factor or identified group?

Carers often take on the financial administration of Direct Payments on behalf of the person they are caring for.

Carers will no longer have to support clients to open a new bank account as the card will be sent directly to the client with a Prepaid Card account ready to be used.


Page 25 of 34

Carers will no longer have to complete the return forms on behalf of clients as this will be recorded online.

A second card can be sent to a carer that links to the same account so they have full access and can make payments online or over the phone in the same way clients managing the payments can.

For carers who receive Direct Payments to support them rather than the person they are caring for, Prepaid Cards will not be used. Once the pilot is complete this will be reviewed.


There is no negative impact on carers

f) Provide details of the mitigation.

See above


Carers will be included in the pilot who support those who receive Direct Payments to ensure feedback is received and monitored.


Page 26 of 34

4.10 Human rights - Human rights place all public authorities – under an obligation to treat you with fairness, equality, dignity, respect and autonomy. Please look at the table below to consider if your proposal, project or service may potentially interfere with a human right.

Articles

A2 Right to life (e.g. pain relief, suicide prevent ion)

A3 Prohibition of torture, inhuman or degrading tre atment (service users unable to consent, dignity of living circumst ances)

A4 Prohibition of slavery and forced labour (e.g. s afeguarding vulnerable adults)

A5 Right to liberty and security (financial abuse)

A6 &7 Rights to a fair trial; and no punishment wit hout law (e.g. staff tribunals)

A8 Right to respect for private and family life, ho me and correspondence (e.g. confidentiality, access to fam ily)

A9 Freedom of thought, conscience and religion (e.g . sacred space, culturally appropriate approaches)

A10 Freedom of expression (whistle-blowing policies )

A11 Freedom of assembly and association (e.g. recog nition of trade unions)

A12 Right to marry and found a family (e.g. fertili ty, pregnancy)

Protocols

P1.A1 Protection of property (service users propert y/belongings)

P1.A2 Right to education (e.g. access to learning, accessible information)

P1.A3 Right to free elections (Elected Members)

Equality Impact Assessment

Page 27 of 34

Part 5 – Conclusions and recommendations for decisi on makers

5.1 Summarise how this proposal/policy/strategy wil l show due regard for the three aims of the general duty across all the p rotected characteristics and ESCC additional groups.

• Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Equality Act 2010;

• Advance equality of opportunity between people from different groups

• Foster good relations between people from different groups

1. Eliminate unlawful discrimination, harassment an d victimisation and other conduct prohibited by the Equality Act 2010;

2. Advance equality of opportunity between people f rom different groups

Overall, the implementation of Prepaid Cards as the method of clients receiving their personal budgets does not change what clients receive, but the method in which they receive it. It is in the design of the card and system that indirect discrimination could arise.

Measures to avoid this include:

• Prepaid cards are accessible to all even if a client would not be able to obtain a bank account they would be able to have a prepaid card.

• For those who are unable to self manage they will not be issued with a prepaid card but have a managed account in the same way that is in place now with A4e, as a result no client will have to use a prepaid card if they do not wish to.

• Prepaid card accounts will have an online and telephone facility to not only use the card but provide guidance on using the card.

• Information made available to clients.

• Real time, light touch monitoring will stop clients having to send in returns forms every four weeks to receive the next batch of funds. For clients who find paperwork a barrier to self managing this will no longer be an issue.

• The addition of a telephone help line means that there is an additional level of support not previously available to clients receiving Direct Payments.

• Other measures are proposed to tackle specific barriers that could arise on the basis of age, disability, transgender identity and ethnicity (see below)

5.2 Impact assessment outcome Based on the analysis of the impact in part four mark below ('X') with a summary of your recommendation.

X Outcome of impact assessment Please explain your answer fully.


Page 28 of 34

A No major change – Your analysis demonstrates that the policy/strategy is robust and the evidence shows no potential for discrimination and that you have taken all appropriate opportunities to advance equality and foster good relations between groups.

X B Adjust the policy/strategy – This involves taking steps to remove barriers or to better advance equality. It can mean introducing measures to mitigate the potential effect.

C Continue the policy/strategy - This means adopting your proposals, despite any adverse effect or missed opportunities to advance equality, provided you have satisfied yourself that it does not unlawfully discriminate

D Stop and remove the policy/strategy – If there are adverse effects that are not justified and cannot be mitigated, you will want to consider stopping the policy/strategy altogether. If a policy/strategy shows unlawful discrimination it must be removed or changed.

As the introduction of Prepaid Cards is a new method of receiving payment, there is no change to any existing process as this does not exist yet.

The points listed below are the areas that have come to light as a result of the assessment and will be out in place at pilot stage so they can be evaluated.

Communication:

Information available in different languages, formats (plain English and LD easy read format) and via different mediums, such as postal mail, the internet and telephone with text relay and minicom.

Customer Service:

The supplier must be aware of ESCC client requirements and able to talk them through any situations they have, including putting them in touch with the DP support team if the questions they have relate to their care plan rather than making a payment.

Text on Prepaid Cards:

The supplier will remove the title on the cards and only print the person’s name.

Evaluation:

Ensure a diverse rage of clients are on the pilot to ensure all areas above are tested in full, evaluated and then reviewed and amended accordingly.


Page 29 of 34

5.3 What equality monitoring, evaluation, review sy stems have been set up to carry out regular checks on the effects of the p roposal, project or service?

An outline of the evaluation process and draft questionnaires can be found in Appendix A. In addition to this interviews and focus groups will be help in order to reach clients who would rather talk about the Prepaid Cards in a group or individually.

5.6 When will the amended proposal, proposal, proj ect or service be reviewed?

Appendix A provides information on how the frequency of evaluation

Date completed: Signed by (person completing)

Role of person completing

Date: Signed by (Manager)


Page 30 of 34

Part 6 – Equality impact assessment action plan

If this will be filled in at a later date when proposals have been decided please tick here and fill in the summary report.

The table below should be completed using the information from the equality impact assessment to produce an action plan for the implementation of the proposals to:

1. Lower the negative impact, and/or 2. Ensure that the negative impact is legal under anti-discriminatory law, and/or 3. Provide an opportunity to promote equality, equal opportunity and improve relations within equality target groups, i.e.

increase the positive impact 4. If no actions fill in separate summary sheet.

Please ensure that you update your service/business plan within the equality objectives/targets and ac tions identified below:

Area for improvement/consideration

at implementation Changes proposed Lead Manager Timescale Resource

implications

Where incorporated/flagged?

(e.g. business plan/strategic

plan/steering group/DMT) Text on Prepaid Cards Removal of title on the

cards LS Before pilot Request from

supplier and check title has been removed

In EIA

Communication sent out Available in different formats

LS Before and during pilot

LD team support will be required to create easy read guidance

As part of the communications planning stage.

Supplier Customer Service Telephone and online assistance in ways that will support clients with different communication and language needs

LS Before pilot – as part of procurement processes when selecting supplier

This will be provided by the selected supplier

A question in the procurement criteria


Page 31 of 34

Monitor membership of pilot by protected characteristics

To ensure all protected characteristics provide feedback this will be reviewed form the questionnaires

LS After the pilot has been running for 6 months

Check questions for characteristics

In the project plan and information collected on the questionnaires

Regular review with supplier

Reviews set up to discuss regular queries that clients call the customer service number with

LS Every 3 months of the pilot stage

Supplier time and LS on Project team

On the time plan to be carried out in the pilot phase.

Practitioner training Effective training to ensure practitioners can relay information regarding Prepaid cards effectively

LS Initial training during implementation phase rolled out across the county

Training team On the project plan


Page 32 of 34

6.1 Accepted Risk

From your analysis please identify any risks not addressed giving reasons and how this has been highlighted within your Directorate:

Area of Risk Type of Risk? (Legal, Moral,

Financial)

Can this be addressed at a later date? (e.g. next

financial year/through a business case)

Where flagged? (e.g. business plan/strategic

plan/steering group/DMT) Lead Manager Date resolved (if

applicable)


Page 33 of 34

Documents

Equality Impact Assessment...Equality Impact Assessment Revised Version 4 Nov 2011 Page 5 of 34 Benefit Group who benefit 1. Supports financial inclusion initiatives. Gives greater