Welsh Assembly and the lost equality impact assessment

[thatdamnedwoman]

The Welsh Assembly produced a 'Welsh Government Action Plan to advance equality for transgender people' in 2016

gov.wales/atisn13028

and said that an impact assessment had been carried out.

A Freedom of Information request was issued on March 2019 asking to see the impact assessment. The Impact assessment appears to have been lost. No trace of it anywhere — even though the Action Plan to Advance Equality for Transgender people mentions the importance of Impact Assessments. Here's the correspondence:

tinyurl.com/y6kxt29n

(I've had to do tinyurl as the original link was so long) It links to whatdotheyknow.com

If anyone here is sitting around at home today with nothing special to do you could check your local council (and possibly also town council and even parish council) on line and find out what resources/ action plans/ policies they have relating to transgender issues. If you find any, you could then use the letters in the whatdotheyknow link above as a template for making an FOI request asking about impact assessments.

My guess is the Welsh Assembly won't be the only body pushing change through without considering the impact on half the population. Let's help reveal this as the scandal we know it to be.

Utter bollocks from the Welsh Assembly speaker there, since drafts and discussions regarding it, and the use of it to inform the planning of the final document would certainly be recorded in minutes of meetings, in email trails between the people involved, and should have been clearly evidenced and referred to in the action plan if not included as appendix to the action plan as an informing document.

FOI request as to who exactly carried out the assessment between what dates, and records of meetings at which this final assessment was discussed and key points considered for the drawing up of the action plan would be useful. However I notice the rep has stated they will not be discussing the matter further. #nodebate

Wholly unacceptable practice whether this is the total screw up and failure of all recording and process that the rep is suggesting, or whether the rep is concealing that it was never done at all and it's better to look incompetent than intentionally negligent to promote a specific political agenda against the interests of others they are paid by and responsible to. Time to inform the ombudsman and the newspapers.

I'm no expert, but having just read the docs and the action plan, it seems that they're admitting they've breached the EA2010 and the Welsh Public Sector Equality Duties 2011 by not having conducted a robust impact assessment.

They are not saying there was no impact assessment, they're seem to be saying there was one and it has vanished without trace.

I suspect the next step is to ask for the minutes of meetings where it was discussed and find out who compiled it and approach them — because surely, someone, somewhere will have kept a copy of the document or preparatory notes or schedules of meetings with the people who were consulted, emails from those people offering their opinion and so on.

If it turns out that no impact assessment was conducted and they've sought to cover that up...

This is astounding. Especially the response "I regret we will be unable to provide any further information" which parses to "Bugger off and stop mithering, we're going to ignore any future questions." Nothing to see here, move along.

Is this the accepted standard of Welsh Assembly performance? Are there any Welsh news media that bothers holding these people to account? I'm left wondering if they are corrupt, incompetent, or both, with the corruption hiding under cover of the incompetence?

Either way it's not a good impression for the Welsh Assembly to be giving. I'd lazily assumed they were better than that, superior to their hidebound counterparts in Westminster. This serves as a wake up call, if the Welsh Assembly has cocked up so spectacularly I am going to have to start keeping a much closer eye on what goes on in local government.

It’s extraordinary that they can say something is lost with such barefaced cheek: we know and they know it was never done.

Nobody loses paperwork like that, these days.
Nobody.

The impact assessment hasn't been done.

And yes they're covering their tracks by saying its gone missing.

We've heard it all before with 'the dog ate my homework'.

Somebody might be frantically muddling together a few notes as we speak.

I predict It will be..

-Backdated
-A hodge podge of cut and paste.
-Sparce on specific detail.

Reminds me of the Calibri font scandal.

My guess is that a woefully inadequate impact assessment was done, a "will this do?" effort, just to allow the Welsh Government to tick that box.

Now that it has to be provided they face a dilemma. Hand it over and undermine their plan. Or lie so they can maintain their claim that the groundwork for the plan was properly done. What a shitty way to carry on.

Shitty and terribly convenient way to carry on.

Thread title sounds like j k Rowling’s latest offering

With persistence and attention to detail, women keep uncovering all this. Because there is such a bloody arrogance about removing women's rights and such an overwhelming sense of superiority and misogyny that institutions just think they don't need to bother. Until someone points out minor things like the laws of the land - and then they scurry around prevaricating, blustering and lying to try to hide it all.
And yes Wrath - it is a man's version of 'the dog ate my homework"

What a shitshow!
There's no way that such a major document could be lost. It either hasn't been done or was started and forgotten about, or even that it was such a woeful effort that when the officer charged with tracking it down for the FoI request actually found it, the document was such an embarrassment that it was deliberately mislaid in the WPB file. (Showing my age here!)

"The most prominent issues raised were the need to consult, listen to and work with trans people when implementing polices which will affect them and also for the Welsh Government to ensure consideration is given to how new policies could impact a transgender person by undertaking Equality Impact Assessments (EIAs)."

It's clear from the above (from section 5 of their trans action plan) that they fucked up by spectacularly missing the point of an Equality Impact Assessment in the first place.

So even if they did one, they openly failed to include women or any other protected classes in the assessment and made it crystal clear in the plan that they'd misunderstood the point of the EIA.

There should be a standard process that would include some form of checklist to verify that all relevant stages had been completed and essential considerations covered. This would include an Impact Assessment.

The record that verified that an Impact Assessment was commenced should also document the appropriate department / section / individual responsible. It should record the date of I.A. completion and the file details and / or link to the relevant file. This should not have been signed off until the checklist was fully completed.
What is going on here? Am I being too suspicious of the Welsh Government and in particular the department / Head of Department responsible?

If it happened it will be evidenced in:

• Who was commissioned or assigned to do this and who wrote the policy as obviously they would have seen the IA before they started work. (names, job titles)
• Email trails of those people during the assessment process
• Specifics on who was consulted and how, and how those decisions were made, the specific timeframes: emails and minutes of meetings
• Minutes of the meetings that planned the policy and the assessment, allocated the work, reviewed the conclusions and identified key points for the policy being written.

ALL of this should be easily retrievable from their systems if it exists. Even meeting minutes will have been emailed out and IT can pull them up.

Will be fascinating to see what happens if all the above evidences that the IA did not take place. Or even if it was raised and it was decided intentionally not to do it. Again, I'm fascinated they'd happily admit to open incompetence because it suggests they're avoiding admitting something worse publicitywise.

The dog ate my impact assessment?

Just placemarking, this is starting to sound like a case for the Equality and Human Rights Commission. Surely they are flouting the public sector equality duty here?

That’s funny, because our local council ( not in wales ) also can’t find their EQIA for making all the single sex spaces ( toilets, showers, changing rooms ) into unisex.

What a huge coincidence.

Morven possibly the dog gets about a lot?

We need a list of all the EQIAs mysteriously gone missing.

If others could find the time to check whether their councils have written policy documents and action plans regarding transgender issues and then do a FOI request to find out whether there were impact assessments done it would be very useful.

IIRC women weren't consulted before the changes to the GRA were proposed. It's beginning to look as if, from Westminster and the WAG down through local and city councils, the impact of change on women is being ignored. One can only wonder about the misogyny demonstrated. They really don't think women matter, do they?

No words here... except, you women are amazing. Thanks for doing all the work this entails. It would be wonderful if an investigative journalist could get on board and run with this too.

This seems like just another element in the huge scandal that is gradually breaking, thanks largely to the wonderful women on this board.

Surely things like this aren't completed by one person? In my company, documents go through various drafts and reviews, with comments added etc. Each version gets emailed round at each stage.

All of those drafts and emails have mysteriously disappeared, have they.

Chinny reckon.

Thanks for this thread, thatdamnedwoman!

Lots (but not all) of Welsh Government stuff is translated into Welsh. So I've been googling relevant words and phrases in Welsh, just in case there might be a Welsh language version that exists somewhere, of an Equality Impact Assessment (EIA) on the Welsh Government Action Plan to advance equality for transgender people.

But no. The dog appears to have eaten the Welsh language version, if it ever existed, as well as the English language version.

In the process - it's amazing how many EIAs miss out on the protected characteristic of sex, but they include "gender" or "gender identity" (which are not protected characteristics in UK law), and sometimes "gender reassignment" as well.

(Just to make it clear that "gender reassignment" in Equality Act 2010 is a protected characteristic, but "gender" and "gender identity" are not.)

Surely things like this aren't completed by one person? In my company, documents go through various drafts and reviews, with comments added etc. Each version gets emailed round at each stage.

If you mean EIA then yes I can believe it was done by one person. The ones I have seen for my council are very basic tick boxes. If it doesn’t raise any issues then it probably wouldn’t even be discussed in a meeting. It would be among the meetings papers though.

So a very hungry Welsh terrier ate the Welsh Language Impact assessment ?
I am stroking my chinny chin chin.