Guidance on equality analysis

Annex D

City of York Council

Equalities Impact Assessment

Who is submitting the proposal?

Directorate:		Housing and Communities Directorate Adult Social Care and Integration Directorate Public Health
Service Area:		Housing Services
Name of the proposal:		Homelessness & Rough Sleeping Strategy, 2024-29
Lead officer:		Andrew Bebbington
Date assessment completed:		14/10/2024
Names of those who contributed to the assessment :
Name	Job title		Organisation	Area of expertise
Andrew Bebbington	Housing Strategy Officer		City of York Council	Housing Strategy

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 Homelessness and Rough Sleeping Strategy 2024-29 will guide work in this area for the following five years and will seek to enlist partners, stakeholders and citizens in a plan to make homelessness rare, brief and non-recurring.

City of York Council (CYC) has a statutory duty to prevent homelessness for its residents under the Homelessness Reduction Act 2017 (HRA) and the Care Act 2014. Under the Homelessness Act 2002, all housing authorities must have in place a Homelessness Strategy based on a review of all forms of homelessness in their district. The strategy must be renewed at least every 5 years. The social services authority must provide reasonable assistance.

The Strategy builds on existing successes and partnerships, offering pathways to suitable housing that can be sustained with high quality, person-centred support. The Strategy is important because it gives focus and structure to the range of services and initiatives which deal with, and seek to prevent, homelessness and rough sleeping. York faces a particular challenge of homelessness because of the shortage of suitable, affordable housing.

The Executive Report sets out the results of the review of York’s homelessness & rough sleeping services including prevention casework, statutory delivery and resettlement pathways and makes recommendations to develop service design, governance and performance frameworks to improve outcomes and value for money. The pathways provide emergency/temporary accommodation and support using residential placements for everyone who is homeless over the age of 16 who needs it. The Housing Options Team, resettlement pathways and partnerships support people to develop the skills to live independently and prevent homelessness.

The Homeless Reduction Act 2017 places a statutory duty on preventing homelessness ensuring timely and accessible housing advice and information is critical to helping people make planned housing moves and avoid a homelessness.

York’s long-term ambition is to have a variety of effective, flexible accommodation and support, with increased levels of homelessness prevention, and a focus upon rapid rehousing. This will be reflected in the refreshed Homelessness and Rough Sleeping Strategy to be consulted on and published in 2024 and is based on ongoing work with DLUHC (Department for Levelling Up, Housing and Communities) and the advice of internationally renowned Homelessness and Rough Sleeping expert Nicholas Pleace based at the Centre for Housing Studies at the University of York.

The proposal will raise equality opportunity for people who share protected characteristics and focus on many of the most vulnerable young people and groups experiencing disadvantages.

1.2

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

The strategy sets a framework for improved partnership work across a range of disciplines, to make better use of resources to improve client wellbeing and value for money across services.

The All-Age Commissioning Strategy, Market Sustainability Plan and the 10-year vision ‘People at the Heart of Care: adult social care reform paper’ clearly outlines that the Council will work with existing Providers within the market to provide sustainable, quality and value for money services. The Care Act 2014 statutory guidance outlines outcomes for individuals, groups and local populations and makes specific references to people with an impairment.

The Council Plan 2023 to 2027, One City, For All, which sets a strong ambition to increase opportunities for everyone living in York to live healthy and fulfilling lives, as follows:

a) Health-Improve health and wellbeing and reduce health inequalities, taking a Health in All Policies Approach.

b) Equalities and Human Rights- Equality of opportunity

c) Affordability- Tackling the cost-of-living crisis.

Young people who become homeless at 16/17 require a joint housing and social care assessment which may deem them as requiring ongoing support under section 20 of the Children Act 1989 (Looked After), whilst it remains appropriate that they live in independent supported accommodation. These young people will now need to be in registered accommodation. The council has a legal duty to prevent and relieve homelessness as set out in Part 7 of the Housing Act 1996, as subsequently amended, and the Homelessness Reduction Act 2017.

1.3

Who are the stakeholders and what are their interests?

Stakeholders: City of York Council Access Team, York and Scarborough Teaching Hospitals, NHS Humber and North Yorkshire Integrated Care Board, Tees Esk Wear Valleys NHS FT, Age UK, Healthwatch, York Advocacy, , Carers Groups/Forums, Youth Homeless Support Worker, Registered Providers (Housing Associations), York College, York CVS, North Yorks Police, Probation, Youth Justice Service, IDAS.

These stakeholders will value a service which effectively prevents homelessness, support children’s wellbeing and delivers long term resettlement outcomes for service users with complex needs, and which delivers health and wellbeing improvements for some of the City’s most vulnerable residents.

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 (2023- 2027) and other corporate strategies and plans.

The Council Plan 2023 to 2027, One City, For All, which sets a strong ambition to increase opportunities for everyone living in York to live healthy and fulfilling lives, as follows:

· Health-Improve health and wellbeing and reduce health inequalities, taking a Health in All Policies Approach.

· Equalities and Human Rights- Equality of opportunity

This are related to the following outcomes for the service.

· Early Intervention and Homelessness Prevention and Relief – reduce homelessness incidence for families and individuals, and act effectively to resolve homelessness where this does occur, minimising the use of unsuitable or inappropriate accommodation and maximising family and individual wellebing

· Prevent, Reduce and Delay the need for ongoing Support- This are related to the statutory duty under Section 2(1) of the Care Act 2024 to contribute towards preventing or delaying the development by adults in its area of needs for care and support. This is related to Health and wellbeing and reducing inequalities within the council plan

· Provide Excellent Experiences of Care and Support- focus on the provision of consistent / joined-up provision, effective promotion of the service, timeliness and responsiveness of the service. Examples of publicity, awareness raising, marketing and promotional activities undertaken. This is related to Health and wellbeing and reducing inequalities within the council plan

· Flexible, Choice and Control- focus on work undertaken to involve customers, families and their carers in the planning of their care and support, evidence of delivering support tailored to the needs of the individual rather than a one size fits all approach, evidence of remaining in ongoing contact with customers, how service provision is internally evaluated and monitored. This is related to Health and wellbeing and reducing inequalities within the council plan

· Linkages and Connections; focus on work undertaken to strengthen the connections between homeless provision and other forms of support for customers - health, housing, voluntary sector provision, leisure, community initiatives etc. Evidence of strong and effective partnership working with a range of other agencies and support organisations. This is related to Health and wellbeing and reducing inequalities within the council plan

· Provision of accessible daily equipment. This is related to Health and wellbeing and reducing inequalities within the council plan

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
Statutory Homelessness: City of York returns https://www.gov.uk/government/collections/homelessness-statistics		Granular data on needs and demand flows and type, reported in a nationally consistent format for the City of York
All Age Market Position Statement, City of York Council, 2023-2025 all-age-market-position-statement-2023-to-2025 (york.gov.uk)		Includes outcomes for City of York Population and outlines key priorities
York Local Health and Wellbeing Strategy 2022-2032, York Joint Health & Wellbeing Strategy		Details the health and wellbeing priorities for the city will be and how these will be addressed
City of York All Age Commissioning Strategy 2023-2025		Includes outcomes for City of York Population as well as detailing key priorities
The Council Plan 2023 to 2027, One City, For All https://www.york.gov.uk/council-plan-1/one-city-2023-2027
Resettlement Services Review exercise undertaken in 2021		Utilise consultation responses and co-production events to inform future service design
Service Performance Data		Understand the existing performance and identify improvement opportunities.

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
Some impacts are not currently monitored as part of the service data collection.		Development of new performance framework of the service to cover the outstanding areas. This would then support the governance arrangements proposed in the strategy to enable continual service improvement, effective delivery, accountability and oversight.

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		Impact identified: Positive impacted of the prevention pathway on individuals: · Families · Single people or couples · Rough sleepers · Young people with Care Leaver social care status The recommendations of the executive report are intended to improve the delivery of homelessness services including for clients with complex needs and protected characteristics and enable to collect better data to understand the positive impact and address negative impact in service delivery. Mitigation: CYC will implement a new data led [performance framework, that will enable continual improvement of service and identify improvements from the data generated within the framework expectations. All services delivered and commissioned by CYC are available to residents of York under the individual service criteria. Further information can be found on the Live Well York site that can be accessed https://www.livewellyork.co.uk/ The Council will comply with all relevant and forthcoming legislation, Equalities Act 2010, Human Rights Act 1998.	Positive (+)	High (H)
Disability		Impact identified: Positive impact of the prevention pathway for individuals who are disabled: · Mental Health · Autism · Learning disability · Sensory impairment · EHCP · Mobility related. The person centred, trauma informed service design and support approach provides additional positive impact to meet these long term needs and achieve sustainable outcomes for groups with mental health needs and other relevant vulnerabilities. The recommendations of the executive report are intended to improve the integration across the resettlement pathway and enable to collect better data to understand the positive impact and address negative impact in service delivery. Mitigation: CYC will implement a new data led performance framework, that will enable continual improvement of service and identify improvements from the data generated within the framework expectations. All services commissioned and delivered by CYC are available to residents of York under the individual service criteria. Further information can be found on the Live Well York site that can be accessed https://www.livewellyork.co.uk/ The Council will comply with all relevant and forthcoming legislation, Equalities Act 2010, Human Rights Act 1998.	Positive (+)	High (H)
Gender		Impact identified: Positive impact of the prevention pathway on individuals including victims of domestic violence: The recommendations of the executive report are intended to improve early intervention and prevention alongside integration across the resettlement pathway and enable to collect better data to understand the positive impact and address negative impact in service delivery. Mitigation: CYC will implement a new data led performance framework, that will enable continual improvement of service and identify improvements from the data generated within the framework expectations. All services commissioned and delivered by CYC are available to residents of York under the individual service criteria. Further information can be found on the Live Well York site that can be accessed https://www.livewellyork.co.uk/ The Council will comply with all relevant and forthcoming legislation, Equalities Act 2010, Human Rights Act 1998.	Positive	Low(L)
Gender Reassignment		Impact identified: The service will continue to provide a person centres approach to take into account individual needs. The recommendations of the executive report are intended to improve the integration across the resettlement pathway and enable to collect better data to understand the positive impact and address negative impact in service delivery. Mitigation: CYC will implement a new data led performance framework, that will enable continual improvement of service and identify improvements from the data generated within the framework expectations. All services commissioned and delivered by CYC are available to residents of York under the individual service criteria. Further information can be found on the Live Well York site that can be accessed https://www.livewellyork.co.uk/ The Council will comply with all relevant and forthcoming legislation, Equalities Act 2010, Human Rights Act 1998.	Positive	Low(L)
Pregnancy and maternity		Impact identified: The service will continue to provide a person centres approach to take into account individuals’ needs. Preventing or resolving homelessness would have a critical impact on the wellbeing of pregnant clients and future family wellbeing. The recommendations of the executive report are intended to improve early intervention and prevention alongside integration across the resettlement pathway and enable to collect better data to understand the positive impact and address negative impact in service delivery. Mitigation: CYC will implement a new data led performance framework, that will enable continual improvement of service and identify improvements from the data generated within the framework expectations. All services commissioned and delivered by CYC are available to residents of York under the individual service criteria. Further information can be found on the Live Well York site that can be accessed https://www.livewellyork.co.uk/	Positive	Low(L)
Race		Impact Identified: Positive impact of the prevention pathway on individuals including: · New refugees · York Gypsy and Travellers group · BAME · People with English as a second language The service will continue to provide a person centres approach to take into account the individual’s needs. The recommendations of the executive report are intended to improve the integration across the resettlement pathway and enable to collect better data to understand the positive impact and address negative impact in service delivery. Mitigation: CYC will implement a new data led performance framework, that will enable continual improvement of service and identify improvements from the data generated within the framework expectations. All services commissioned and delivered by CYC are available to residents of York under the individual service criteria. Further information can be found on the Live Well York site that can be accessed https://www.livewellyork.co.uk/	Positive	Medium (M)
Religion and belief		Impact Identified: The service will continue to provide a person centres approach to take into account the individual’s needs. The recommendations of the executive report are intended to improve the integration across the resettlement pathway and enable to collect better data to understand the positive impact and address negative impact in service delivery. Mitigation: CYC will implement a new data led performance framework, that will enable continual improvement of service and identify improvements from the data generated within the framework expectations. All services commissioned and delivered by CYC are available to residents of York under the individual service criteria. Further information can be found on the Live Well York site that can be accessed https://www.livewellyork.co.uk/	Positive	Low(L)
Sexual orientation		Impact Identified: The service will continue to provide a person centres approach to take into account the individual’s needs. The recommendations of the executive report are intended to improve the integration across the resettlement pathway and enable to collect better data to understand the positive impact and address negative impact in service delivery. Mitigation: CYC will implement a new data led performance framework, that will enable continual improvement of service and identify improvements from the data generated within the framework expectations. All services commissioned and delivered by CYC are available to residents of York under the individual service criteria. Further information can be found on the Live Well York site that can be accessed https://www.livewellyork.co.uk/	Positive	Low(L)
Children with experience of care		Impact identified: Positive impact of the prevention pathway for individual with experience of care as children. The strategy pathways incorporate specialist, person-centred support and housing services for this group. The recommendations of the executive report are intended to improve early intervention and prevention alongside integration across the resettlement pathway and enable to collect better data to understand the positive impact and address negative impact in service delivery. Mitigation: CYC will implement a new data led performance framework, that will enable continual improvement of service and identify improvements from the data generated within the framework expectations. All services commissioned and delivered by CYC are available to residents of York under the individual service criteria. Further information can be found on the Live Well York site that can be accessed https://www.livewellyork.co.uk/ The Council will comply with all relevant and forthcoming legislation, Equalities Act 2010, Human Rights Act 1998.	Positive (+), High
Other Socio-economic groups including :		Could other socio-economic groups be affected e.g. carers, ex-offenders, low incomes?
Carer		Impact Identified: Positive impact of the prevention pathway on individuals including: · Unpaid Carers · Adult carers · Young Adult Carers · Young Carers · Children in Care The service will continue to provide a person centres approach to take into account the individual’s needs. The recommendations of the executive report are intended to improve the integration across the resettlement pathway and enable to collect better data to understand the positive impact and address negative impact in service delivery. The recommendations of the executive report are intended to improve the integration across the resettlement pathway and enable to collect better data to understand the positive impact and address negative impact in service delivery. Mitigation: CYC will implement a new data led performance framework, that will enable continual improvement of service and identify improvements from the data generated within the framework expectations. All services commissioned and delivered by CYC are available to residents of York under the individual service criteria. Further information can be found on the Live Well York site that can be accessed https://www.livewellyork.co.uk/	Positive	Medium(M)
Low income groups		Impact Identified: Positive impact of the prevention pathway on individuals including · Loss of employment · Debt and financial crises. · Cost of living crises The service will continue to provide a person centres approach to take into account individual needs. The recommendations of the executive report are intended to improve the integration across the resettlement pathway and enable to collect better data to understand the positive impact and address negative impact in service delivery. The recommendations of the executive report are intended to improve the integration across the resettlement pathway and enable to collect better data to understand the positive impact and address negative impact in service delivery. Mitigation: CYC will implement a new data led performance framework, that will enable continual improvement of service and identify improvements from the data generated within the framework expectations. All services commissioned and delivered by CYC are available to residents of York under the individual service criteria. Further information can be found on the Live Well York site that can be accessed https://www.livewellyork.co.uk/	Positive	Medium(M)
Veterans, Armed Forces Community		The City of York has signed the Armed Forces veteran’s covenant. It is an agreement that no one who has ever served in the Armed Forces, or their families, should be disadvantaged because of their service. In practice, this does not mean that Armed Forces personnel receive preferential treatment compared to other people, but that everyone agrees to work together to ensure that the Armed Forces community can access the same level of service as non-serving citizens Mitigation: Senior Officers are actively engaged in the Armed Forces Covenant Executive Steering group to develop data collection and performance monitoring in respect of this group. Effective Information Communication Technology (ICT) systems will be utilised where appropriate to understand outcomes and to inform service development. All services commissioned by CYC are available to residents of York under the individual service criteria. Further information can be found on the Live Well York site that can be accessed https://www.livewellyork.co.uk/ The Council will comply with all relevant and forthcoming legislation, Equalities Act 2010, Human Rights Act 1998.	Positive	Low(L)
Other		Employee Wellbeing Support To continue to support the wellbeing of our staff during this demanding and difficult time, the Employee Wellbeing Line and email has been setup. The service is for all staff HR related queries, worries or concerns; relating to working hours, pay, health or wellbeing. Email: employeewellbeing@york.gov.uk
Impact on human rights:
List any human rights impacted.		There will be a positive impact for Human Rights by delivering the council’s statutory responsibilities and bringing partners together to embed early intervention and improve systems through joint working and outcomes monitoring. Ongoing reflection and feedback from users of the service to learn and improve Human Rights and Equalities Board. The City of York Council and the York Human Rights City Steering Group established the Human Rights and Equalities Board with a remit to: provide strategic direction for the council’s human rights and equalities work tackle the issues raised within the York Human Rights City Indicator Report Any services being developed and put in place to provide person centred care must adhered to these principles.	Positive (+)	Medium

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?

There will be no negative impact on the above groups and subsequent customers of the Homeless Services. Any impacts will be managed as part of an assessment of individuals needs and care and support services will be designed in accordance with information provided by the customer.

The council will ensure that information about the Homeless Reduction Act 2017, advice and support is accessible to agencies and partners. In addition the Council will ensure advice and prevention tools are relevant to tackling the main structural causes of homelessness – housing supply and poverty. The council will ensure the prevention tools are relevant to tackling the main causes of homelessness like relationship breakdown and loss of tenancies.

Deploy the most effective early intervention and prevention tools:

• The council will support access to financial advice, skills and employment services.

• The council will build on skills and workforce within the voluntary sector partners to deliver free and independent debt advice and identify those at risk of homelessness at an early stage.

The service will not change in any way that will have detrimental equality impact on individuals, the council will be delivering services in accordance with the robust specification.

Solutions in the above EIA have been provided to provide reassurance that any impacts that we foresee will be minimised by the actions outlined in the EIA.

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		Conclusions/justification
No major change to the proposal		The impacts from the proposals are limited, and expected to be positive with mitigations in place to deliver on these aims.

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
Equality and Human Rights Act		Quality Assurance	Laura Williams

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?

The approach to the market for the Homeless service reflects the journey outlined in our delivery and commissioning Strategy as this has been developed to focus on outcomes and principles for commissioning services, in line with the Council’s Strategy and plan. Each contract will have Key Performance Indicators that will measure the outcomes with our providers included in the specifications. Training and outcomes expressed as part of the returned surveys will be incorporated into key documents.

The new focus on person-centred, trauma informed, partnership delivery is expected to have a positive impact that will be monitored and will inform learning. Any future changes will be assessed at the time they are proposed; however, it is unlikely that any of these will have a negative impact.

City of York Council

Equalities Impact Assessment

- 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.