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Legal Basis of Equality Impact Assessments (EQIAs) Requirement in Scotland under Equality Act 2010 to: Assess the impact of applying a new or revised policy/ practice against the needs of the general equality duty (note: this includes updates, amendments and decisions too). Consider evidence relating to people across protected characteristic (PCs). Take account of these findings. Review and revise to ensure compliance with the general equality duty. Publish results within a reasonable period.
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EQIAs and General Equality Duty A public authority must, in the exercise of its functions, have due regard to the need to: a) Eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by the Act; * b) Advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it; c) Foster good relations between persons who share a relevant protected characteristic and persons who do not share it. * With the exception of marriage & civil partnership, all protected characteristics are subject to the full duty. The duty also covers marriage & civil partnerships for section a) in employment only.
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Key Evidence Considerations when Conducting EQIAs Although data sources have improved considerably, there are monitoring and benchmarking challenges: Gender reassignment and sexual orientation are not included in Scottish Census 2011; only estimates are available. SFC does not require Colleges to monitor gender reassignment; however your College might collect this. SFC makes the monitoring of religion, but not belief, and sexual orientation voluntary; however your College might collect this.
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Key Evidence Considerations when Conducting EQIAs Although data sources have improved considerably, there are monitoring and benchmarking challenges: SFC disability fields do not include the “Learning Disability (for example Down’s Syndrome)” Census field. Issues with age ranges across data sources, e.g. 16 to 19, 20 to 24 vs 16 to 20, 21 to 25. “White” and “BME” ethnic fields do not account for “UK White”, “Other White” and “BME” groups. Issues with clarity of definitions in relation to Plain English, additional support needs, or international students, e.g. “heterosexual”.
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Equality Impact Assessments: Our Procedure Expected Outcomes and Potential Impact Expected Outcomes and Potential Impacts Consider Relevant Evidence Consider Alternatives and Mitigation Compliance with General Equality Duty Involvement of Groups Representing PCs Making a Decision Taking Action and Monitoring
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Equality Impact Assessment of Admissions Competitive process - 24,000 applicants for 6,000 full time places. Consistent application process - Entry Requirements, Selection Criteria and Interviews. Customer base - 9 Protected Characteristics
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Method Cross College Working Group. Student Association Teaching staff Marketing Team Equalities Staff Quality/Performance Student Funding Admissions Team Learning Support Core Skills Staff ECU Pre Application Marketing Materials Entry Qualifications Selection Criteria Advice and Guidance Course Content Applicant Selection Interview Structure Interview Assessments Scoring Methods Feedback
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Findings - Age Applications from under 16s discouraged. Issues around safeguarding. Legitimate legislation i.e. use of chemicals in hairdressing industry. Applications from ‘mature’ applicants without entry qualifications accepted. Being ‘mature’ is not a criteria. Having relevant life or work experience is the important factor. How can this be evidenced? Requirement for references mentioned School i.e. PE Teacher. References from School not applicable after a certain age. Create a barrier if School experience not good.
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Recommendations Remove any direct or indirect references to age. Publish the minimum level entry criteria for all. Consider the need for a reference and what it adds. Selection criteria should be publish together with information on how this can be evidence by the applicant (this is in addition to entry criteria).
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Findings - Disability Glasgow City Council 21% Scottish Census 19% College Enrolments 14% College Offers 11% College Applications 9% Faculties Creative Ind 12% Education and Society 10% Leisure and Lifestyle 9% Business 7% Build, Eng, Energy 7%
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Findings and Recommendations- Disability Full time attendance not feasible Alternative modes. Varying Access Points. Positive images and case studies in marketing materials in areas such as sport and hair and beauty. Avoid tokenism. Consider current student testimonials. Consider the need for references and what this adds. Possible undetected disability/learning difficulty in the past could impact disproportionately in the requirement to provide references.
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Findings – Race (Ethnicity) Faculties Business 12% Build, Eng, Energy 9% Education and Society 9% Leisure and Lifestyle 6% Creative Ind 4% Glasgow City Council 12% College Applications 9% College Offers 8% College Enrolments 8% Scottish Census 4%
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Findings and Recommendations – Race (Ethnicity) Selection Criteria. Is there an opportunity for different cultures to evidence ability. Consider the need for references and what this adds. Might pose a barrier for those with ‘new’ residency status. Course levels and entry qualifications should be referenced to the SCQF to assist with mapping and comparison of overseas qualifications.
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Recurring Themes References. Do they create barriers? Ask - Who? What? Why? Create a reference template – standardise. The range of selection elements require robust scoring and weighting. Qualifications. Interview performance. Selection criteria. References. Need for a consistent interview experience - training. Meaningful feedback to applicants.
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Benefits Provides an evidence based frame work for questioning current practice and introducing improvements. Highlights areas of tension within strategies i.e. Performance Indicators vs Access & Inclusion. Facilitates discussion. Recurring themes are ‘quick wins’ which can lead to substantial improvements in processes. A range of intangible benefits. Improved awareness and understanding of protected characteristics.
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