An Equity Analysis Tool is an evidence-based approach designed to help organisations ensure that any Policy, Criterion or Practice (PCP), is fair and does not create barriers to participation or disadvantage any protected groups from participation. This covers both strategic and operational activities.
City of York Council (CYC) combines this approach with York’s commitment as a Human Rights City to produce a Human Rights and Equity Analysis Tool (HREAT).
This document enables CYC to evidence its legal duty to give ‘due regard’ to those with protected characteristics under the Equality Act and consider Human Rights at the same time.
Whether a HREAT is needed or not will depend on the likely impact that a PCP may have and relevance of the activity to Equity and Human Rights.
The HREAT should be started when the need for a new PCP is first identified, or when an existing one is reviewed. It is essential to continue to update the HREA during the life of the PCP, as and when new information is learned. It is not complete until the PCP is complete.
Non-discrimination is a minimum standard. The development of the HREAT should prompt critical discussion and highlight disproportionate impacts.
Balancing residents’ rights and CYC duties can be very complex and sometimes there will be no ‘win-win’, so compromises or mitigations may need to be identified to ensure the best outcomes.
Finally, the value in a HREAT is in both the short and long term, by investing in this process CYC will create robust, meaningful, and empowering policies that are more likely to stand the test of time.
Directorate |
City Development |
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Service Area |
City Development |
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Name of proposal |
Executive Report – City Centre Events and Permanent Anti-Terrorism Traffic Regulation Order |
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Lead Officer |
Ben Murphy, Head of City Development |
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Date Assessment Started |
January 2026 |
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Date Assessment Completed |
February 2026 |
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Names of those who contributed to the assessment |
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Name |
Job Title |
Organisation |
Area of Expertise |
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Ben Murphy |
Head of City Development |
City of York Council |
City Development |
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David Smith |
Access Officer |
City of York Council |
Accessibility |
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Laura Swiszczowski |
Head of Equity, Diversity and Inclusion |
City of York Council |
Equity, Diversity & Inclusion |
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1.1 |
What is the purpose of the proposal |
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Please explain your proposal in plain English avoiding acronyms and jargon. Consider using Age 9 English. |
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The report considers the impacts of city centre events (including York Christmas Market), including benefits and disbenefits to communities, and in the context nationally of greater security and control of vehicular movement in high footfall areas, and locally of consultation on potential permanent ATTRO. The report sets out proposed approaches to managing these events moving forward, including co-design of accessibility improvements with key communities of interest. |
1.2 |
Are there any external considerations? |
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Legislation / government directive / codes of practice etc. |
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Relevant legislation includes: · Equality Act 2010, which aims to protect people from discrimination in the workplace and in wider society. The Act includes a Public Sector Equality Duty, which requires public bodies to consider how their decisions and policies affect people with protected characteristics. The public body also should have evidence to show how it has done this It also requires that public bodies have due regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations between different people when carrying out their activities. The Equality Act 2010 covers the following protected characteristics: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. · Human Rights Act –sets out the fundamental rights and freedoms that everyone is entitled to. In making a decision the council must consider carefully the balance to be struck between individual rights and the wider public interest and whilst it is acknowledged that there could be interference with a Convention right, the decision must be reasonably justified as it is a proportionate means of achieving a legitimate aim. · Approved Document M Access to the use of Buildings Volume 2 Buildings other than dwellings · BS 8300-2:2018 Design of an accessible and inclusive built environment. Buildings - code of practice / Inclusive Mobility Guidance (Department for Transport 2005) · Protect Duty consultation documents (www.gov.uk/government/consultations/protect-duty) · Hostile Vehicle Mitigation guidance (www.gov.uk/government/publications/crowded-places-guidance/hostile-vehicle-mitigation-hvm#vehicle-as-a-weapon-vaw) · The Blue Badge scheme: rights and responsibilities in England (www.gov.uk/government/publications/the-blue-badge-scheme-rights-and-responsibilities-in-england) · Road Traffic Regulation Act 1984 and associated regulations relating to TROs, under which local traffic authorities in England and Wales (outside London) may make permanent orders for the following purposes: o To avoid danger to persons or other traffic using the road or any other road or to prevent the likelihood of any such danger arising; o To prevent damage to the road or to any building on or near the road; o To facilitate the passage on the road or any other road of any class of traffic (including pedestrians); o To prevent the use of the road by vehicular traffic of a kind which, or its use by vehicular traffic in a manner which, is unsuitable having regard to the existing character of the road or adjoining property; o To preserve the character of the road in a case where it is specially suitable for use by persons (…) on foot; o To preserve or improve the amenities of the area through which the road runs; or o To preserve or improve local air quality. · The Business and Planning Act which creates a de-regulated approach to pavement cafes. o The Terrorism (Protection of Premises) Bill (or Martyn’s law), has also now achieved royal assent, and entered into a period prior to full implementation by April 2027.
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1.3 |
Who are the stakeholders and what are their interests? |
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Consider both internal and external stakeholders. |
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Key stakeholders for the proposals include · Disabled people including Blue Badge holders, and those living with impairments illnesses or conditions which affect how they use the city centre · Older people · Young people including those of differing school ages and their parents or carers · Other groups visiting the pedestrian area and accessing its shops and services, · City centre businesses and service providers (e.g. deliveries, trades, etc). · North Yorkshire Police and relevant anti-terrorism organisations Their interests are wide ranging and include suitable access by a range of transport modes (private car, taxi/private hire, deliveries, cycling, walking), safety, and services and amenities available in the foot street area. |
1.4 |
What results / outcomes do we want to achieve and for whom? |
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Explain what outcomes you want to achieve for stakeholders, staff and the wider community. Demonstrate how the proposal links to the Council Plan (2023- 2027) and other corporate strategies and plans. Highlight how the proposal meets the objectives of Equalities, Affordability, Climate and Health. |
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The Council Plan contains four key commitments one of which is Equalities and Human Rights - Equality of opportunity and states “We will create opportunities for all, providing equal opportunity and balancing the human rights of everyone to ensure residents and visitors alike can benefit from the city and its strengths. We will stand up to hate and work hard to champion our communities” The work seeks to improve the accessibility of the city centre for all, through a roadmap of co-designed improvements over the short medium and long term |
3.1 |
What sources of data, evidence and consultation feedback have you used to help understand the impact of the proposal on equality rights and human rights? |
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Please consider a range of sources, including consultation exercises, surveys, feedback from staff, stakeholders, participants, research reports, the views of equality groups, as well your own experience of working in this area etc. |
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Source of data / supporting evidence |
Reason for using this source |
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Consultation and engagement |
A wide range of consultation and engagement on related issues has already been undertaken, including through: · the My City Centre Engagement · City Centre Access Project · November 2021 Executive decisions. Additionally and since the most recent October and November 2025 Executive reports, further engagement has taken place involving key stakeholders including members of both the York Disability Rights Forum and York Access Forum. Extensive engagement and consultation will be undertaken with key stakeholders as part of the Movement and Place work, which will define the long term plan for the centre. |
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Research reports |
For the August 2019 Executive report, approving the permanent changes to the Traffic Regulation Order to deliver the Phase 1 Hostile Vehicle Mitigation proposals in the city centre: · an independent review of Blue Badge Parking Access was also commissioned from Parking Perspectives a consultancy specialising in parking. · In addition, Disabled Motoring UK, a charity and advocacy group for disabled people, were commissioned to produce an independent review of York’s disabled access offer · The November 2020 executive report commissioned a Strategic Review of City Centre Access in order to identify potential improvements to city centre access · Martin Higgitt Associates also produced an independent report · In 2024 a follow up accessible city consultation was carried out by MIMA Accessibility Consultants All of the above have informed the approach set out in March report, and will shape the further work including ongoing activity of the officer task and finish group, and the Movement and Place plan |
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Surveys |
City Centre Access project As part of this work, parking surveys were undertaken in the streets listed above in May 2019. This shows 86 parking events / day in the Goodramgate corridor, of which 80 vehicles displayed a Blue Badge. 86 parking events / day were also recorded on the Blake Street corridor, of which 49 vehicles displayed a Blue Badge. |
3.1 |
Equality-related obligations derive from the Equality Act of 2010 and the Human Rights Act of 1998. |
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Once you have engaged with stakeholders you will need to identify how this proposal impacts on their human rights and equalities. Although the table below one looks complex, its purpose is to facilitate an initial screening of equalities and human rights impacts of your proposal. Many human rights and equalities will not be affected by the decision you are seeking Executive or Council approval for and so can be left blank. The aim here is to identify pressure points regarding human rights and equalities that require attention. Please see the Appendix for details of the protected characteristics and human rights to consider The rights listed below in the first column are the relevant ones from the Human Rights Act, and the York Human Rights City Network Indicator Report (non-discrimination, education, health and social care, housing, a decent standard of living). The human rights in the Indicator Report were selected by residents of York as their priority rights. In the first row the protected characteristics under the Equality Act are listed, to which ‘Everyone’ has been added to capture impacts that affect everyone without distinction. |
EqualitiesHuman Rights |
Everyone |
Age including financial, digital exclusion impacts |
Disability Including financial, digital exclusion impacts |
Gender |
Gender reassign-ment Including Trans, Non-binary, Intersex |
Marriage and civil partnership |
Pregnancy and maternity |
Race |
Religion and belief |
Sexual orientation |
Carers inc financial, digital exclusion impacts |
Low-income groups inc financial, digital exclusion impacts |
Veteran, armed forces community |
Those with experience of Care |
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Right to life* |
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x |
x |
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x |
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x |
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x |
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Prohibition of torture* |
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Prohibition of slavery and forced labour* |
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Right to liberty, movement and security (including freedom of movement)*** |
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x |
x |
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x |
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x |
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X |
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Right to a fair trial* |
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No punishment without law* |
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Right to private and family life*** |
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Freedom of thought, conscience, and belief*** |
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Freedom of expression*** |
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Freedom of assembly*** |
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X |
x |
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x |
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x |
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x |
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Right to marry*** |
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Right to property*** |
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x |
x |
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x |
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x |
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x |
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Right to education*** |
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Right to free elections*** |
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Right to housing*** |
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Here you will need to record the details on all the impacts identified for both Human Rights and those with Protected Characteristics.
Where you have identified an impact on a protected characteristic / human right in the table above, please indicate whether this is positive or negative and give a description of this impact. If you run out of rows, please add as necessary.
Where rights clash or are being restricted, you will need to explain how the decision has been taken, that the limitation on human rights is provided by law, for a legitimate purpose (justified), and proportionate (the minimum necessary restriction on rights).
First, think about what equalities or rights might be engaged by the proposal, and describe the likely impact of the proposal, and provide an evaluation.
Use the following questions to inform your responses if human rights or equalities are limited or qualified in any way:
· Why are a person’s rights being restricted?
· What is the problem being addressed by the restriction on someone’s rights?
· Will the restriction lead to a reduction in the problem?
· Does that restriction involve a blanket policy, or does it allow for different cases to be treated differently?
· Does a less restrictive alternative exist?
· Has sufficient regard been paid to the rights and interests of those affected?
· Do safeguards exist against error or abuse?
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Positive or Negative impact |
Impact Description |
Evaluation or justification |
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Age including financial, digital exclusion impacts |
Positive |
The report proposes the continuation of events in the city centre, maintaining the status quo, but proposes improvements to how the city centre is currently accessed, as part of a co-designed pathway to longer term accessibility improvements too, benefitting older people who are statistically more likely to have impairments of this type. |
In respect to a full ATTRO closure, the options identified may help to mitigate some of the challenges faced by older or younger people. |
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Disability Including financial, digital exclusion impacts |
Positive |
The report proposes the continuation of events in the city centre, maintaining the status quo, but proposes improvements to how the city centre is currently accessed, as part of a co-designed pathway to longer term accessibility improvements too, benefitting people with disabilities. |
In respect to a full ATTRO closure, the options identified may help to mitigate some of the challenges faced by disabled people |
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Gender |
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Gender Reassignment Including Trans, Non-binary, Intersex |
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Marriage and civil partnership |
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Pregnancy and maternity |
Positive |
The report proposes the continuation of events in the city centre, maintaining the status quo, but proposes improvements to how the city centre is currently accessed, as part of a co-designed pathway to longer term accessibility improvements too, benefitting this group. |
In respect to a full ATTRO closure, the options identified may help to mitigate some of the challenges faced by people who meet this particular protected characteristic. |
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Race |
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None identified |
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Religion and belief |
Positive |
issues with access to religious venues within the protected area |
In respect to a full ATTRO closure, the options identified may help to mitigate some of the challenges faced by people who would like to practice their religion or belief at venues within the protected area |
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Sexual orientation |
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Carers including financial, digital exclusion impacts |
Positive |
The report proposes the continuation of events in the city centre, maintaining the status quo, but proposes improvements to how the city centre is currently accessed, as part of a co-designed pathway to longer term accessibility improvements too, benefitting carers, many of whom look after people with disabilities. |
In respect to a full ATTRO closure, the options identified may help to mitigate some of the challenges faced by people who meet this particular protected characteristic. |
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Low-income groups inc financial, digital exclusion impacts |
Positive |
Blue Badge Parking is free within CYC Car Parks for both disabled and non-disabled parking bays as long as the Blue Badge is Displayed. Blue Badge users can also park on double yellow lines (where there are no restrictions of obstructions) for 3 hours as well as in ResPark bays, without any time limit or cost. |
In respect to a full ATTRO closure, the options identified may help to mitigate some of the challenges faced by people who meet this particular protected characteristic. |
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Veteran, armed forces community |
Positive |
Many veterans from the armed forces have a disability and the outcomes identified above would be the same for disabled veterans. |
In respect to a full ATTRO closure, the options identified may help to mitigate some of the challenges faced by people who meet this particular protected characteristic. |
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Those with experience of Care |
Positive |
The report proposes the continuation of events in the city centre, maintaining the status quo, but proposes improvements to how the city centre is currently accessed, as part of a co-designed pathway to longer term accessibility improvements too, benefitting carers, many of whom look after people with disabilities. |
In respect to a full ATTRO closure, the options identified may help to mitigate some of the challenges faced by people who meet this particular protected characteristic. |
4.1 |
What are the main gaps in information and understanding of the impact of your proposal? |
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When conducting your screening, you may have discovered gaps in data or knowledge that make it difficult to assess whether your proposal had a positive or negative impact on human rights/equalities. Please indicate actions you will take to resolve this gap. As your proposal progresses you may be able to resolve this knowledge gap –please indicate when it was resolved. |
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Gaps in data or knowledge |
Action to deal with this |
Date resolved |
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Strategic and long term approach to accessibility and movement in city |
Undertake Movement and Place study, to include in depth engagement and consultation with impacted communities |
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5.1 |
What has been done to optimise opportunities to advance equality / human rights or foster good relations? |
6.1 |
Having considered the potential or actual impacts you should be in a position to make an informed judgement on what should be done. In all cases, document your reasoning that justifies your decision. |
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Important: If there are any adverse impacts you cannot mitigate, please provide a compelling reason in the justification column. There are four main options you can take: |
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No major change to the proposal |
The HREAT demonstrates the proposal is robust. There is no potential for unlawful discrimination or adverse impact and you have taken all opportunities to advance equality / human rights and foster good relations, subject to continuing monitor and review. |
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Adjust the proposal |
The HREAT identifies potential problems or missed opportunities. This involves taking steps to remove any barriers, to better advance quality or to foster good relations. |
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Continue with the proposal (despite the potential for adverse impact) |
You should clearly set out the justifications for doing this and how you believe the decision is compatible with our obligations |
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Stop and remove the proposal |
If there are adverse effects that are not justified and cannot be mitigated, you should consider stopping the proposal altogether. If a proposal leads to unlawful discrimination it should be removed or changed. |
Option Selected |
Conclusion / justifications |
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No major change to officer recommendation |
7.1 |
What action, by whom, will be undertaken as a result of the impact assessment. |
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List below the actions or mitigations that have been identified and who will be responsible to carrying them out. Add as many lines as you need. |
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Impact / Issue |
Actions to be taken |
Person Responsible |
Timescale |
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Accessibility of the city centre |
Implementation of the proposed accessibility improvement measures as referenced at paragraph 26 of the report |
Co-designed with officer group |
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Accessibility of the city centre |
Work with CYC Officers and disabled people in York on engagement and implementation of any co-produced and agreed recommendations |
David Smith |
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8.1 |
How will the impact of your proposal be monitored and improved upon going forward? |
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Consider how will you identify the impact of activities on protected characteristics, other marginalised groups and human rights going forward? How will any learning and enhancements be capitalised on and embedded? |
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Ongoing co-design of accessibility improvements, and engagement and consultation on strategic plans including Movement and Place plan |
Under the public sector duties introduced by the Equality Act 2010 public bodies must have due regard for the need to:
· Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the act, such as the failure to make reasonable adjustments for disabled people
· Advance equality of opportunity between people who share a protected characteristic and those who do not
· Foster good relations between people who share a protected characteristic and those who do not
These duties relate to the nine protected characteristic groups defined by the Equality Act 2010 (outlined in the table below).
The Council recognises that a person’s socio-economic background and whether they live in a rural or urban location can be important factors in determining fair access to services, employment and treatment. When carrying out analysis, you must also consider socio-economic issues and rural / urban location issues. In addition to the nine protected characteristic the HREAT includes the following equality groups:
· Carers
· Low income groups
· Veterans, armed forces community
· Experience of care/Other (other groups that are impacted)
- First, human rights apply to everyone and not just groups with protected characteristics.
- Second, they allow for the balancing of rights, priorities, and risks. Many rights are not absolute and can be limited or qualified in particular circumstances.
The following guidance identifies which rights are most likely to be engaged by proposals in certain policy areas. This doesn’t mean that you should not consider whether other rights might be engaged.
There are three types of human rights in the Human Rights Act:
- Absolute rights – cannot be breached in any circumstances e.g. right to life and to protection from torture and inhuman or degrading treatment.
- Limited rights – can only be restricted in specific situations e.g. a person can be deprived of their liberty if they are convicted of an offence and imprisoned.
- Qualified rights – human rights can be restricted if it is in the interests of the wider community or to protect other people’s rights e.g. freedom of movement and assembly were restricted during the Covid-19 pandemic in the interests of public health.
As limited and qualified rights are not absolute, they sometimes have to be balanced in decision making. In Table 1, absolute rights are indicated with an *; limited rights with a **; and qualified rights with a ***.
Right |
Description[1] |
Focus Area |
Right to life |
Nobody, including the Government, can take someone’s life away. Public authorities must take appropriate measures to safeguard life including by protecting people whose life might be in danger. Public authorities should also consider the right to life when making decisions that might endanger or affect life expectancy. When public officials may be involved in an instance when someone died, public authorities must conduct an investigation. |
· Benefits and money · Births, deaths and marriages · Children and families · Environment and animals · Health and social care · Housing · Planning and building · Waste and recycling |
Freedom from torture and inhuman or degrading treatment |
Torture consists in causing very serious and cruel physical or mental pain or suffering. Inhuman treatment or punishment is treatment which causes intense physical or mental suffering. Degrading treatment means treatment that is extremely humiliating and undignified. Inhuman or degrading treatment could include: serious physical assault; very severe detention conditions or restraints; serious physical or psychological abuse in a health or care setting. |
· Children and families · Health and social care
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Prohibition of slavery and forced labour |
Slavery is when someone owns someone else like a piece of property. Servitude is when someone provides services to a person for no reward and is unable to stop due to coercion. Forced or compulsory labour is when someone is forced to do work to which they have not agreed to, under the threat of punishment. |
· Children and families · Jobs, training and volunteering · People and communities |
Right to liberty and security |
It focuses on protecting individuals’ freedom from unreasonable detention, as opposed to protecting personal safety. However, there is case law from other jurisdictions where this right also covers personal safety in conditions other than detention. Under the HRA 1998 and the ECHR, it means that no one can be imprisoned or detained without good reason. |
· Health and social care · Housing · People and communities
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Right to a fair trial |
This right is triggered when someone is charged with a criminal offence and have to go to court, or a public authority is making a decision that has an impact on someone’s civil rights or obligations. |
· Environment and animals · Health and social care · People and communities · Streets, roads and pavements |
No punishment without law |
No one can be charged with a criminal offence for an action that was not a crime when it was committed. Public authorities must explain clearly what counts as a criminal offence so that people know when they are breaking the law. |
· Environment and animals · People and communities · Streets, roads and pavements |
Right to private and family life, home and correspondence |
This includes one’s right to determine their sexual orientation, lifestyle, and the way one looks and dresses. It also includes the right to control who sees and touches one’s body. It further covers one’s right to develop their personal identity and to forge friendships and other relationships, the right to participate in essential economic, social, cultural and leisure activities. In some circumstances, public authorities may need to facilitate the enjoyment of one’s right to a private life, including their ability to participate in society. It also means that personal information about anyone (including official records, photographs, letters, diaries and medical records) should be kept securely and not shared without their permission, except in certain circumstances. |
· Benefits and money · Births, deaths and marriages · Children and families · Health and social care · Jobs, training and volunteering · Parking and permits · Planning and building · Schools and education · Sports and leisure |
Freedom of thought, conscience and belief |
This may include the right to change religion or beliefs, the right to put one’s thoughts and beliefs into action, for example by exercising the right to wear religious clothing, the right to talk about one’s own beliefs or take part in religious worship. Public authorities cannot stop anyone from practising their religion, without very good reason. This right protects a wide range of non-religious beliefs including atheism, agnosticism, veganism and pacifism. |
· Business · Schools and education |
Freedom of expression |
This includes the right to express views aloud (for example through public protest and demonstrations) or through published articles, books or leaflets, television or radio broadcasting, works of art, the internet and social media. It further protects the right to receive information from other people by, for example, being part of an audience or reading a magazine. |
· Business · Environment and animals · People and communities · Schools and education · Sports and leisure |
Freedom of assembly and association |
This encompasses the right to form and be part of a trade union, a political party or any another association or voluntary group. Nobody has the right to force anyone to join a protest, trade union, political party or another association. |
· Environment and animals · Jobs, training and volunteering · People and communities · Travel and transport · Streets, roads and pavements |
Right to marry and start a family |
Right of men and women of marriageable age to marry and to start a family. |
· Births, deaths and marriages · Children and families |
Right to property |
No public authority, without very good reason can take away one’s property, which may include things like land, houses, objects, shares, licences, leases, patents, money, pensions and certain types of welfare benefits. This right applies to companies as well as individuals. |
· Benefits and money · Business · Council tax · Environment and animals · Housing · Planning and building · Travel and transport · Streets, roads and pavements · Waste and recycling |
Right to education |
This right protects one’s right to an effective education within the UK's existing educational institutions. It relates to primary, secondary, and higher education. Parents have a right to ensure that their religious and philosophical beliefs are respected during their children’s education. |
· Children and families · Environment and animals · Jobs, training and volunteering · People and communities · Schools and education · Sports and leisure |
Right to free elections |
Public authorities must support the right to free expression by holding free elections at reasonable intervals. These elections must enable anyone to vote in secret. |
· Births, deaths and marriages · People and communities |
Right to housing |
Adequate housing must provide more than four walls and a roof. For housing to be adequate, it must, at a minimum, meet the following criteria:
Security of tenure, that is legal protection against forced evictions, harassment and other threats; availability of services, materials, facilities and infrastructure; affordability, which means that housing is not adequate if its cost threatens or compromises the occupants’ enjoyment of other human rights; Habitability, which relates to physical safety or adequate space, as well as protection against the cold, damp, heat, rain, wind, other threats to health and structural hazards; accessibility, in that it must accommodate the specific needs of disadvantaged and marginalised groups; location, which means that it must not be cut off from employment opportunities, health-care services, schools, childcare centres and other social facilities, or it must not be located in polluted or dangerous areas; cultural adequacy, which means that it must respect and take into account the expression of cultural identity. |
· Benefits and money · Housing · People and communities · Planning and building · Waste and recycling |
[1] The wording of each description box has been adapted from the following sources: Equality and Human Rights Commission or British Institute for Human Rights.