City of York Council

Equalities Impact Assessment

Who is submitting the proposal?

Directorate:		Housing and Communities
Service Area:		Housing
Name of the proposal :		Tackling ASB statement of policy
Lead officer:		Rachael Bassett/Fiona Brown
Date assessment completed:		26/09/2025
Names of those who contributed to the assessment:
Name	Job title		Organisation	Area of expertise
Rachael Bassett	Housing Services Change Manager		City of York Council	Housing
Fiona Brown	Business Change Manager		City of York Council	Housing
Imogen Kerr	Assistant Housing Policy Officer		City of York Council	Housing

Step 1 – Aims and intended outcomes 

1.1

What is the purpose of the proposal? Please explain your proposal in Plain English avoiding acronyms and jargon.

The key aim of City of York Council’s Anti-Social Behaviour Policy and associated procedures is to ensure that the council, acting in its landlord capacity, applies correct and appropriate working practices to the task of tackling Antisocial behaviour (ASB) in York. In working towards this aim, the council recognises the need to inform tenants and leaseholders of the City of York of its policy, and of the need to involve the communities in developing effective ways to tackle ASB. The ASB policy also serves to outline the expectations of tenant conduct and provides framework for addressing and preventing ASB in the community.

1.2

Are there any external considerations? (Legislation/government directive/codes of practice etc.)

· . Environmental Act 1995 & Environmental Protection Act 1990                      Domestic abuse Act 2021 · Social Housing (Regulation) Act 2023 · Noise Act 1996 · Data Protection Act 2018 · The Protection from Harassment Act 1997 · Crime and Disorder Act 1998 · Human Rights Act 1998 · Freedom of Information Act 2000 · Criminal Justice and Police Act 2001 · Police Reform Act 2002 · Anti-Social Behaviour Act 2003 · Children’s Act 2004 · Housing Act 1985, 1996 & 2004 · Safeguarding Vulnerable Groups Act 2006 · Equality Act 2010 · Anti-Social Behaviour Act 2003 and Police Reform and Social Responsibility Act 2011 · ASB, Crime and Policing Act 2014 · Misuse of Drugs Act 1971

1.3

Who are the stakeholders and what are their interests?

The policy applies to all tenants and leaseholders but as ASB affects others the wider community will also be a stakeholder.  Internal stakeholders include building services and housing management.   Other organisations such as the Police, adult and children services, voluntary support agencies, other council depts also may be involved in instances of ASB. These services will be interested how the council expects ASB to be dealt with and prevented.

1.4

What results/outcomes do we want to achieve and for whom?  This section should explain what outcomes you want to achieve for service users, staff and/or the wider community. Demonstrate how the proposal links to the Council Plan (2019- 2023) and other corporate strategies and plans.

The intended outcomes are: · To ensure that tenants and leaseholders understand what ASB is and how it will be dealt with by the Housing team. · To ensure that Housing and Council staff are aware of the procedure to deal with ASB. · To ensure that any reports of ASB are dealt with in the correct, legal, transparent and fair manner. Ensuring that both the victim and perpetrator are given the necessary support and guidance needed to resolve ASB cases. · To ensure cases are dealt with in a timely manner. Through the publication of the policy to allow other stakeholders to understand how ASB will be dealt with. Aligns with the council core commitment and priority in the following ways: · Health and Wellbeing by dealing with ASB in an effective and transparent way we are trying to ensure that residents can live well in their homes. · Equalities and Human rights by ensuring that we take a zero approach to ASB we contribute to residents’ quiet enjoyment of their homes.

Step 2 – Gathering the information and feedback 

2.1	What sources of data, evidence and consultation feedback do we have to help us understand the impact of the proposal on equality rights and human rights? 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.
Source of data/supporting evidence		Reason for using
Co production with Tenants Voice and Tenants Scrutiny		To ensure that the tenants voice is heard
Complaints about ASB		As above and to ensure that we are learning from complaints
Housing Ombudsman Spotlight report on Noise Nuisance and learning from severe Maladministration July 2025 report Consultation with the Community Safety Hub		To ensure that we are considering recommendations from the Housing Ombudsman As a key stakeholder in how we deliver our ASB policy, we worked with the Community Safety in producing the ASB policy
Consultation with Green and Burton ASB associates		To ensure that we have taken into consideration good practice in the sector

Step 3 – Gaps in data and knowledge

3.1	What are the main gaps in information and understanding of the impact of your proposal?  Please indicate how any gaps will be dealt with.
Gaps in data or knowledge		Action to deal with this

Step 4 – Analysing the impacts or effects.

4.1	Please consider what the evidence tells you about the likely impact (positive or negative) on people sharing a protected characteristic, i.e. how significant could the impacts be if we did not make any adjustments? Remember the duty is also positive – so please identify where the proposal offers opportunities to promote equality and/or foster good relations.
Equality Groups and Human Rights.		Key Findings/Impacts	Positive (+) Negative (-) Neutral (0)	High (H) Medium (M) Low (L)
Age		There is no lower or upper age limit to being a victim or perpetrator of anti-social behaviour. Different approaches may be required for engaging with different age groups, which could be inconsistently delivered across the council.	0
Disability		Different approaches may be required for engaging with disabled people  depending on their individual needs. This may result in inconsistent approaches delivered across the council. · Mental health is a complex area. Some complainants and victims of anti-social behaviour may have a reduced level of mental well-being generally and as a result of issues of anti-social behaviour suffer greater impacts. · It is also recognised and acknowledged that some perpetrators of anti-social behaviour have mental health problems. There is a link between mental health problems and drug/alcohol use for both perpetrators and complainants. · The behaviour of a disabled person can be mistakenly perceived as being ASB	-	m
Gender		ASB affects all genders. The policy covers all genders in terms of victims and perpetrators, therefore access to services is not affected by gender	0
Gender Reassignment		There are no direct impacts from the policy in respect of gender reassignment.	0
Marriage and civil partnership		No issues identified	0
Pregnancy and maternity		No issues identified	0
Race		There is a risk that Minority Ethnic communities may feel isolated and may be unsure or unaware of the procedure for reporting anti-social behaviour.	-	M
Religion and belief		ASB can involve offences relating to a victim’s religion and beliefs. The policy seeks to mitigate these impacts	-	M
Sexual orientation		ASB can involve offences relating to a victim’s sexual orientation. The policy seeks to mitigate these impacts	-	M
Other Socio-economic groups including :		Could other socio-economic groups be affected e.g. carers, ex-offenders, low incomes?
Carer		No issues identified	-
Low income groups		Crime, poverty and ASB could be connected but this policy could reduce impacts for people	+
Veterans, Armed Forces Community		No issues identified.  Conditions such as PTSD could  a trauma impact on a resident when and so care needs to be taken to be proportionate and reasonable.	-
Other		Ex offenders with complex needs may need more support and guidance to keep a healthy tenancy and a strong ASB policy may help with thus	+	N
Impact on human rights:
List any human rights impacted.		Right to private and family life – service users may feel this policy is impacting negatively on their right to private and family life, by defining their behaviour as anti social. However, this needs to be balanced against the rights of residents around them and the role of the public authority to facilitate the enjoyment of one’s right to housing, free from harassment (e.g. some forms of ASB could constitute harassment).

Use the following guidance to inform your responses:

Indicate:

- Where you think that the proposal could have a POSITIVE impact on any of the equality groups like promoting equality and equal opportunities or improving relations within equality groups

- Where you think that the proposal could have a NEGATIVE impact on any of the equality groups, i.e. it could disadvantage them

- Where you think that this proposal has a NEUTRAL effect on any of the equality groups listed below i.e. it has no effect currently on equality groups.

It is important to remember that a proposal may be highly relevant to one aspect of equality and not relevant to another.

High impact (The proposal or process is very equality relevant)	There is significant potential for or evidence of adverse impact The proposal is institution wide or public facing The proposal has consequences for or affects significant numbers of people The proposal has the potential to make a significant contribution to promoting equality and the exercise of human rights.
Medium impact (The proposal or process is somewhat equality relevant)	There is some evidence to suggest potential for or evidence of adverse impact The proposal is institution wide or across services, but mainly internal The proposal has consequences for or affects some people The proposal has the potential to make a contribution to promoting equality and the exercise of human rights
Low impact (The proposal or process might be equality relevant)	There is little evidence to suggest that the proposal could result in adverse impact The proposal operates in a limited way The proposal has consequences for or affects few people The proposal may have the potential to contribute to promoting equality and the exercise of human rights

Step 5 - Mitigating adverse impacts and maximising positive impacts

5.1

Based on your findings, explain ways you plan to mitigate any unlawful prohibited conduct or unwanted adverse impact. Where positive impacts have been identified, what is been done to optimise opportunities to advance equality or foster good relations?

The policy will ensure that as consistent an approach as possible is followed throughout the council. Information about the service and reporting procedures can be made available, on request, in different languages, large print and braille. Interpreters can also be made available, on request. Regular review of ASB activities undertaken in respect of the policy and perpetrator/victim race to ensure these groups is not being disadvantaged. Access to service is also considered and home visits are available. Referrals to support agencies are also available. Mental Health and reporting hate crime training has been provided for Housing Staff. The policy engages with tenants and leaseholders throughout the whole of the ASB case, providing support tailored to individual needs. Risk Impact Assessments are carried out for all victims and complainants to assess what support may be necessary. All complainants and victims are offered referrals to support agencies, such as Victim and Witness Support. The policy highlights that any hate related incidents will not be tolerated, and reports of Hate crimes will be prioritised.

Step 6 – Recommendations and conclusions of the assessment

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. There are four main options you can take:
- No major change to the proposal – the EIA demonstrates the proposal is robust.  There is no                         potential for unlawful discrimination or adverse impact and you have taken all opportunities to    advance equality and foster good relations, subject to continuing monitor and review.
- Adjust the proposal – the EIA identifies potential problems or missed opportunities. This involves taking steps to remove any barriers, to better advance quality or to foster good relations. - 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 under the duty - 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. Important: If there are any adverse impacts you cannot mitigate, please provide a compelling reason in the justification column.
Option selected No major change to the proposal		Conclusions/justification The analysis demonstrates that any adverse impacts can be mitigated and referrals to support services can be made for those that may need them.

Step 7 – Summary of agreed actions resulting from the assessment

7.1	What action, by whom, will be undertaken as a result of the impact assessment.
Impact/issue		Action to be taken	Person responsible	Timescale
Disability		Review all policies and processes relating to ASB for social model of disability language and inclusive language on mental health (e.g. vulnerability)	Fiona Brown
		Regular review of ASB activities undertaken in respect of the policy and perpetrator/victim to ensure that no group is being disadvantaged.

Step 8 - Monitor, review and improve

8. 1	How will the impact of your proposal be monitored and improved upon going forward?   Consider how will you identify the impact of activities on protected characteristics and other marginalised groups going forward? How will any learning and enhancements be capitalised on and embedded?
	Regular review of ASB activities undertaken in respect of the policy and perpetrator/victim to ensure that no group is being disadvantaged.