The Welsh Government have done an Equality Impact Assessment

[FOIrequester]

At least, they have done something which they call an Equality Impact Assessment.

Last month I asked the Welsh Government for their Equality Impact Assessment for their new draft LGBTQ+ Action Plan. Their response is here.

www.whatdotheyknow.com/request/equality_impact_assessment_for_t_13#incoming-1874563

The Action Plan was published in July, and I made my request on 14th August. The publication date of the Equality Impact Assessment is 31st August, so it doesn't seem to have existed at the time the Action Plan was published.

The document they have sent isn't really an Equality Impact Assessment because an EIA is supposed to show the impact on people with all protected characteristics, but this one only covers gender reassignment and sexual orientation. It doesn’t mention how their plan might affect (for example) children, elderly people, disabled people. It only mentions LGBTQ+ children, LGBTQ+ elderly people, LGBTQ+ disabled people, and so on.

They have form for failing to do impact assessments, and then claiming that they have been misplaced and no trace of them can be found. Which is very strange considering how many people would have been involved in e-mailing each other during the course of compiling a risk assessment, and it having to be written out in both Welsh and English.

They let trans lobby groups write their homework for them, and then tell obvious lies when challenged. Not a good look. Cowardly, dishonest and incompetent.

This seems to be a common theme. I had always thought that EIAs should look at impact on all of the protected characteristics but the Scottish Government and now the Welsh seem to think it means assessing the impact only on the characteristic that is being targeted.

Surely the newspapers are interested in this kind of thing? Private Eye magazine too has excellent coverage of political scandals, but you have to send them the information as they haven’t got a lot of staff.

I think the Welsh government need biology lessons!

FoI I admire your tenacity and demand for accountability in all this, I really do applaud you knowing how long you've been after this!

Interesting that they finally managed to get an EqIA off their dog before it ate this one too.

Even more interesting that yet again they have no ruddy clue on how to do one properly, what it's for, why it matters, or even why you do one before making decisions and action plans as it's supposed to ruddy inform your thinking.....

The average village hall playgroup knows better practice than this Mickey Mouse outfit. Who can you report this massive, massive failure of basic standards to?

This is typical for public sector organisations now. I have no idea who trains them or even explains what an EqIA is, but I can't recall a single one done properly in this area.

They either simply write no impact anywhere but LGBT, or they think that the other protected characteristics are only there for those who are LGBT plus another protected characteristic, which they then vaguely look at (so, disabled LGBT staff, religious LGBT staff etc) or they think an EqIA is only there to assess how the proposed measure will impact on the group that is the target of the measure. Which is just too stupid.

I have no idea who trains them or even explains what an EqIA is, but I can't recall a single one done properly in this area.

I would be willing to bet on a number of possibilities:

• that the trainers were from a political lobby with a specific agenda in which they had a personal stake
• that the trainers had no training at all in any other characteristic but the one that affected them personally
• that they mis explained what an EqIA is and how it worked
• that they quite possibly did not know or understand this itself, however this made this political action work entirely to their advantage and against the interests and equality of other protected groups
• that no one ever did any due diligence on booking these trainers

This is typical for public sector organisations now. I have no idea who trains them or even explains what an EqIA is, but I can't recall a single one done properly in this area.

I strongly agree.

I can't think of a decent or well-rounded one that I've ever seen for healthcare. Inequality considerations tend to reflect the perspective of a particular single interest only. I suspect you're correct that nobody knows how to do them and now the whole arena is more contentious there is no prospect of conducting one that considers all of the protected characteristics or relevant considerations.

So how do we go about challenging them is there a body like the ICO or is it the Local government ombudsman

I found a tool that they could have used to help them here.

www.wlga.wales/equality-impact-assessment-in-wales-practice-hub

The Equality Impact Assessment in Wales Practice Hub has been developed by the Welsh Local Government Association, Welsh Government, Public Health Wales and NHS Centre for Equality and Human Rights to provide an online information and good practice resource. Its aims are to support the NHS and local government organisations in Wales to build their strategic capacity in relation to equality impact assessments (EIA) and to improve the level and quality of their equality evidence, research and EIA practice.

Presumably the Welsh Government itself isn't mentioned in that list of organisations this information is designed to help, because as they were partially responsible for its creation they should be aware of its contents and know that they should follow the same procedure for their own policies.

They should have paid particular attention to Step 3 - Assessment of Impact.

Negative impact is usually unintentional, which is why it’s important to conduct an EIA – this will help you identify and address negative impacts

phw.nhs.wales/services-and-teams/equality-impact-assessment-in-wales-practice-hub/equality-impact-assessment/

It should be obvious to anyone that if you only assess the impact on the group(s) of people that the policy is designed to help, you won't identify unintentional negative impacts on other groups.

Also from Step 1:
The assessment should be started prior to policy development or during policy design

Not done in a hurry after the policy has gone out to consultation when someone makes an FOI request.

How is it that the Equality Branch of the Welsh Government doesn't understand what an Equality Impact Assessment is for or how to carry one out?

They just look like fucking idiots. A mix of deliberately incompetent, clueless and allowing the thugs to run things.

I think things like this are so important because this is where the change is going to take place - when we show public and private organisations that they can't get away with this shit.

So who do we complain to?

@NewMutiny

I think things like this are so important because this is where the change is going to take place - when we show public and private organisations that they can't get away with this shit.

So who do we complain to?

I've been having a look around and it's so far coming up with ways in which LAs and the NHS can protect themselves against vexatious complaints such as challenging the completeness of an EqIA but not a way to protest about them.

I'll persevere but I could do with knowing the answer to this.

I found this interesting reading and it’s really disappointing to say the least. You are correct @FOIrequester that it should identify the unintended negative impacts but doesn’t. The link to the integrated impact assessment highlights sex, religion and other protected characteristics but it’s all far too positive and glosses over any potential negative impacts.

It’s also only been completed by one officer from one perspective, which is not best practice, and so is not a comprehensive IA but barely a screening stage. It’s also not evidence based, does not use stakeholders consultation feedback and does not include any robust evidence to back up the points made.

Yes who do we complain to
Senedd members
MP’s
High courts?
Let me know
This is awful

Does the Assembly have a Disability contact and a Religious representative and a Race representative or is it all the same ‘equality’ team? If not, Is it worth contacting external lobby groups for their input?

gov.wales/wales-race-forum
Sadly looks like the same team.

They do have a stats team, justice team and a legal team
gov.wales/contacts-statistics

gov.wales/contact-welsh-government-legal-services-electronically

gov.wales/justice-stakeholder-group

This is the big problem. Bugger all accountability, meaning they get away with this abysmal, unhanded misuse of power and responsibility.

This is why we cannot let the government get rid of judicial review; its one of the few remaining ways to try and force people to follow their own bloody rules and policies.