Section 75 Screening Form - Sign Language Interpretation of Plenary and Committee Business

The Commission’s Equality Scheme reflects the ECNI’s definition of a policy and this should be applied in determining what needs to be screened. The Equality Scheme states:

“In the context of Section 75, ‘policy’ is very broadly defined and it covers all the ways in which we carry out, or propose to carry out, our functions in relation to Northern Ireland. In respect of this equality scheme, the term policy is used for any (proposed / amended / existing) strategy, policy initiative or practice and/or decision, whether written or unwritten and irrespective of the label given to it, e.g. ‘draft’, ‘pilot’, ‘high level’ or ‘sectoral’.”

If you are in doubt, please contact the Equality and Good Relations Unit for advice. Equality screening guidance notes are also available on Assist.

Part 1 Policy scoping

The first stage of the screening process involves scoping the policy under consideration.  The purpose of policy scoping is to help prepare the background and context, and to set out the aims and objectives for the policy being screened. At this stage, scoping the policy will help identify potential constraints as well as opportunities and will help the policy maker work through the screening process on a step-by-step basis.

The ECNI, in their ‘model equality screening form’, note that public authorities should remember that the Section 75 statutory duties apply to internal policies (relating to people who work for the authority), as well as external policies (relating to those who are, or could be, served by the authority).

Policy Details

Name of the policy to be screened/description:

Sign Language Interpretation of Plenary and Committee Business

Is this policy an existing, new or revised policy? (Please append policy to screening form)

New Policy

What is it trying to achieve? (brief outline of intended aims/outcomes of the policy)

In November 2021 the Assembly Commission approved a pilot for the provision of live sign language interpretation of Question Time to the Executive Office Ministers to the end of the mandate.  The pilot was in both British Sign Language (BSL) and Irish Sign Language (ISL) and was made available on the Assembly Website.  The resignation of the First Minister on 3 February 2022 meant that Question Time to the Executive Office could not continue. As a result, the pilot was continued with interpretation provided for questions to other Executive Ministers.  In April – May 2022, a review of the pilot was undertaken with representatives from the deaf community, the interpreters and internally with the various business areas involved in the delivery of the pilot.  The main finding was that the pilot was well received by the deaf community, who indicated a desire for a continuation of the pilot.     SMT has now agreed that the pilot should be continued with the aims of

• increasing access for the Deaf Community to the business of the Assembly with specific reference to Question Time to Executive Ministers which takes place in the Assembly Plenary each week that the Assembly is sitting;
• certain special events such as the first sittings in a new mandate, tributes such as that to Her Late Majesty, VIP addresses to the Assembly, etc. are sign language interpreted
• bringing the Assembly’s provision of sign language interpretation closer to that provided in other legislatures;
• allow the Assembly to respond proactively in the context of growing expectations and potential statutory duties being placed on public bodies relating to accessing services;
• helping to deliver on the Assembly Commission’s Corporate Plan objective of Strengthening Engagement with the Public;
• prepare the Assembly for the introduction of a potential Sign Language Bill.

The New Decade New Approach agreement committed the Department of Communities to the introduction of a Sign Language Bill to the Assembly.  The Bill was not introduced in the 2017 – 2022 mandate but is expected to be introduced in the 2022 – 2027 mandate. 

It is expected that the Assembly Commission will at the appropriate time set aside sufficient resources to engage with the Deaf Community and sign the passage of the Bill through the Assembly, including its committee stages. 

Are any of the Section 75 categories which might be expected to benefit from the intended policy/decision? Please explain how.

Yes – this policy will have direct benefit to Deaf and Hard of Hearing Communities who are considered as falling within the S75 category of ‘persons with a disability and persons without’.

Who initiated or wrote the policy?

Stella McArdle

Directorate responsible for devising and delivering the policy?

Parliamentary Service

Was consultation carried out as part of this screening exercise?

Yes

Background to the Policy to be screened

Include details of any pre- consultations/consultations which have been conducted and whether the policy has previously been tabled at SMT/ Assembly Commission meetings.

In November 2021 the Northern Ireland Assembly Commission approved a pilot for the provision of live sign language interpretation of Question Time to the Executive Office Ministers to the end of the mandate.  The pilot was to be in both British Sign Language (BSL) and Irish Sign Language (ISL) and to be made available on the Assembly Website.  The pilot ran in parallel to the manual subtitling of Question Time to the Executive Office that was available on playback after Question Time rather than in real time.   The resignation of the First Minister on 3 February 2022 meant that Question Time to the Executive Office could not continue. As a result, the pilot was continued with interpretation provided for questions to other Executive Ministers.   The pilot covered eight events one of which was the Tribute to the Late Christopher Stalford MLA.

The Pilot recognised that profoundly Deaf people view sign language as their ‘language of need’ and that without signing in the two predominant sign languages in Northern Ireland (BSL & ISL) access, insight and understanding of the role of the Assembly was restricted.  For many sign language users, BSL & ISL is the first or preferred means of communication and are used by themselves and their families and friends.   A Department of Culture, Arts and Leisure consultation document states

‘For many Sign Language users, spoken and/or written language is their second or even third language. As with all linguistic minorities, members of the Deaf community have varied levels of English. While some Sign Language users are fully bilingual in both Sign Language and English, many have limited literacy skills. This means that misunderstandings can easily arise, especially when using more complex concepts or grammar, or less common words. As such, like many other minority language users, Sign Language users can’t necessarily read or understand information on Government websites or printed leaflets and various types of literature.’

An informal advisory group composed of both individuals from the hearing and deaf community representing Deaf Community advocacy groups (local and national), individuals from the Deaf Community, sign language interpreters, and a child of deaf adult (CODA) was established to provide a conduit of information flow and learning back and forth between the advisory group into the deaf community itself and the Assembly representatives interacting with it.  The work of this group was invaluable in providing input on many aspects of the pilot. 

Sign language interpreters were procured using the Department of Finance (DoF), Central Procurement Division (CPD) Lot 3 of the ‘Framework for Interpretation, Translation and Transcription Service’.

In April – May 2022, a review of the pilot was undertaken with representatives from the deaf community, the interpreters and internally with the various Assembly business areas involved in the delivery of the pilot.  The main finding is that the pilot was well received by the deaf community, who have now indicated a desire for more interpretation services.  A number of challenges were also identified including

• A shortage of interpreters available locally, in particular ISL, with only a few willing to undertake parliamentary interpretation due to the live broadcast element.
• Dedicated broadcasting space - during the pilot, a temporary studio was created but a number of issues relating to the space and broadcasting were identified.  Work is underway to identify a studio space and a recent / on-going upgrade of the Assembly Broadcasting infrastructure will help to address this issue.

Research has indicated that all other parliaments in the UK and Ireland routinely provide sign language interpretation for Prime Minister’s / Leader’s Question Time and a varying range of other matters ranging from Ministerial Statements, matters of national importance, major debates such as on the Budget etc.  There are variations in the amount of live and retrospective signing, as well as signing of Committee Business. 

In November 2022, SMT agreed that the pilot should be continued, with a signing of Plenary Business, normally Question Time, relevant Committee Business (on an ad hoc basis) and other certain special events such as the first sittings in a new mandate, tributes, VIP addresses to the Assembly etc.

Implementation factors

Are there any factors which could contribute to/detract from the intended aim/outcome of the policy/decision?

No

Main stakeholders affected

Who are the internal and external stakeholders (actual or potential) that the policy will impact upon?

• Staff
• The Deaf and hard of hearing community
• Other users of Parliament Buildings such as contractors.

Other policies with a bearing on this policy

What are these policies and who owns them? Please list:

The following NI Assembly Commission policies are relevant

• NIAC Equality Scheme,
• NIAC Audit of Inequalities,
• NIAC Good Relations Strategy,
• NIAC Disability Action Plan.   

Consideration of available data/research

(This means any data or information you currently hold in relation to the policy or have gathered/generated during policy development). Evidence to inform the screening process may take many forms and should help you to decide who the policy might affect the most. It will also help ensure that your screening decision is informed by relevant data.

What evidence/information (both qualitative and quantitative) have you gathered to inform this policy? For example, is there any evidence of higher or lower participation or uptake by different groups? Specify details for each of the Section 75 categories.

There is very little qualitative evidence/information about the Deaf and Hard of Hearing Communities.  Findings from the Continuous Household Survey published by DfC in October 2022 stated the following (please note that this data is not referring to deaf adults)

‘Knowledge of Sign language. In 2021/22, one out of ten adults (10%) in Northern Ireland were able to communicate using Sign language. Females (13%) were more likely to have knowledge of Sign language than males (7%).

Adults who have dependants were more likely to have knowledge of Sign language compared to those who do not have dependants (13% and 9% respectively).

In 2021/22, adults living in the least deprived areas were more likely to have knowledge of Sign language than those living in the most deprived areas (13% and 9% respectively).

There was no significant difference found between adults who live in rural areas compared to urban areas regarding knowledge of Sign language (10% and 11% respectively).

Similarly, no significant difference was found between adults who have a disability and those who do not have a disability (12% and 10% respectively).

Note: As with 2020/21, due to the coronavirus (COVID-19) pandemic, data collection for the 2021/22 survey moved from face-to-face interviewing to telephone mode with a reduction in the number of questions. The results from the CHS 2021/22 are not directly comparable to previous years due to the significant changes to the survey in terms of methodology and content.’

The DfC website also states the following

‘Northern Ireland has two signed languages - British Sign Language (BSL) and Irish Sign Language (ISL). Both BSL and ISL were embraced within the Belfast/Good Friday Agreement and in March 2004 the Secretary of State announced the formal recognition of BSL and ISL as languages in their own right following similar recognition of BSL in Great Britain.

The languages have their own grammar and syntax systems rather than being visual reflections of other languages. BSL is the first or preferred language of communication of approximately 3,500 members of the deaf population of Northern Ireland while approximately 1,500 use ISL.

Deaf culture and identity

Deaf people who use sign language as their first or preferred language identify themselves as part of a cultural and linguistic minority and view their signed language as a ‘language of need’ which, along with deaf culture, should be respected and celebrated.

New Decade New Approach / Legislation

In March 2016, the Department for Communities consulted on a Sign Language Framework, which contained policy proposals for legislation. This consultation was referenced in the New Decade New Approach agreement in January 2020 with a commitment to introduce a Sign Language Bill. The Department is currently working towards this commitment’

Taking into account the information referred to above, what are the different needs, experiences and priorities of each of the following categories, in relation to the particular policy/decision?  and what is the actual or likely impact on equality of opportunity for those affected by the policy. (See appendix 1 for information on levels of impact).

Specify details of the needs, experiences and priorities for each of the Section 75 categories below:

Section 75 category

Religious belief

Needs/experiences/priorities/impacts: N/A

Impact Level: None

Political opinion

Needs/experiences/priorities/impacts: N/A

Impact Level: None

Racial group

Needs/experiences/priorities/impacts: The Northern Ireland Census 2021 gathered data on the main languages in Northern Ireland, focused on spoken languages.  The first spoken language in NI is English and the second is Polish.  The Census estimates that 20,124 or 1.1% of the Northern Ireland population of usual residents aged three and over had Polish as their main language.  A watching brief will be kept on the possible emergence of a need to sign in other languages such as Polish Sign Language.

Impact Level: Minor Impact

Age

Needs/experiences/priorities/impacts: It is recognised that for some people, hearing loss is a component of aging.  Many of those experiencing age related hearing loss will have an understanding of written language and therefore have access to parliamentary proceedings via the Official Report and / or the sub titling used for some plenary business.

Impact Level: Minor Impact

Marital status  

Needs/experiences/priorities/impacts: N/A

Impact Level: None

Sexual orientation

Needs/experiences/priorities/impacts: N/A

Impact Level: None

Men and women

Needs/experiences/priorities/impacts: N/A

Impact Level: None

Disability

Needs/experiences/priorities/impacts: The Deaf and hard of hearing communities are considered as falling into this category   Deaf people who use sign language as their first or preferred language identify themselves as part of a cultural and linguistic minority and view their signed language as a ‘language of need’ which, along with deaf culture, should be respected and celebrated.  It is recognised that some sign language users are fully bilingual in signing and English.  However, many have limited literacy skills.  It is recognised that this can lead to misunderstandings around complex concepts and specialist language both of which are common in parliamentary proceedings.  This can mean that sign language users can not automatically read or understand parliamentary information or language.  One further aspect of this that is worth mentioning is that this has led to an underdevelopment of sign language for many parliamentary concepts and language.  This aspect was identified during the Pilot by the interpreters who have begun a process of developing appropriate signs.  It is hoped that this aspect will be continued in conjunction with the Deaf Community.

Impact Level: Minor Impact

Dependants

Needs/experiences/priorities/impacts: Information taken from the Continuous House Survey noted that Adults who have dependants were more likely to have knowledge of Sign language compared to those who do not have dependants (13% and 9% respectively).

Impact Level: None

If you do not have enough data to tell you about potential or actual impacts, you may need to generate more data to distinguish what groups are potentially affected by your policy.

Part 2 Screening Questions

What is the likely impact on equality of opportunity for those affected by this policy, for each of the Section 75 equality categories?

Section 75 category

Religious belief

Issues: N/A

Impact Level: None

There are no specific equality issues relating to the sign language pilot that have been identified for this equality category.

Political opinion

Issues: N/A.

Impact Level: None

There are no specific equality issues relating to the sign language pilot that have been identified for this equality category.

Racial group

Issues: As above.  

Impact Level: None

There are no specific equality issues relating to the sign language pilot that have been identified for this equality category.

Age

Issues: As above

Impact Level: None

There are no specific equality issues relating to the sign language pilot that have been identified for this equality category.

Marital status    

Issues: N/A  

Impact Level: None

There are no specific equality issues relating to the sign language pilot that have been identified for this equality category.

Sexual orientation

Issues: N/A

Impact Level: None

There are no specific equality issues relating to the sign language pilot that have been identified for this equality category.

Men and women generally

Issues: N/A

Impact Level: None

There are no specific equality issues relating to the sign language pilot that have been identified for this equality category.

Disability

Issues: As above

Impact Level: Minor Impact

It is recognised that some sign language users are fully bilingual in signing and English.  However, many have limited literacy skills.  It is recognised that this can lead to misunderstandings around complex concepts and specialist language both of which are common in parliamentary proceedings. 

Dependants

Issues: N/A

Impact Level: None

There are no specific equality issues relating to the sign language pilot that have been identified for this equality category.

Are there any actions which could be taken to reduce or mitigate any adverse impact which has been identified or opportunities to better promote equality of opportunity for people within the section 75 categories?

Section 75 category

Religious belief

Issue: N/A

Impact Level: None

No specific equality issues have been identified for this equality group. 

Political opinion

Issue:  N/A

Impact Level: None

No specific equality issues have been identified for this equality group. 

Racial group

Issue:  Keep a watching brief on the possibility that people from a different racial background living in Northern Ireland, may require signing in a difference sign language.

Impact Level: Minor Impact

Age

Issue: as above

Impact Level: None

No specific equality issues have been identified for this equality group. 

Marital status

Issue: N/A

Impact Level: None

No specific equality issues have been identified for this equality group. 

Sexual orientation

Issue: N/A

Impact Level: None

No specific equality issues have been identified for this equality group. 

Men and women generally

Issue: N/A

Impact Level: None

No specific equality issues have been identified for this equality group. 

Disability

Issue: As above – this policy will have a positive impact for the Deaf and hard of hearing Community

Impact Level: Minor Impact

Dependants

Issue: N/A

Impact Level: None

No specific equality issues have been identified for this equality group.

To what extent is the policy likely to impact on good relations between people of different religious belief, political opinion or racial group?

Good relations category

Religious belief

Details of policy Impact: N/A

Impact Level: None

This policy will be a benefit to deaf and hard of hearing people from all communities, but no specific good relations issues have been identified in the screen of this policy. 

Political opinion

Details of policy Impact: N/A

Impact Level: None

This policy will be a benefit to deaf and hard of hearing people from all communities, but no specific good relations issues have been identified in the screen of this policy.

Racial group

Details of policy Impact: N/A

Impact Level: None

This policy will be a benefit to deaf and hard of hearing people from all communities, but no specific good relations issues have been identified in the screen of this policy. 

Are there opportunities to better promote good relations between people of different religious belief, political opinion or racial group?

Section 75 category

Religious belief

If Yes, provide details: N/A

If No, provide reasons:  

This policy will enhance communications to the deaf and hard of hearing communities, we have not identified any specific opportunities to promote good relations through the operation of this pilot.   

Political opinion

If Yes, provide details: N/A

If No, provide reasons:  

This policy will enhance communications to the deaf and hard of hearing communities, we have not identified any specific opportunities to promote good relations through the operation of this pilot.   

Racial group

If Yes, provide details: N/A

If No, provide reasons:  

This policy will enhance communications to the deaf and hard of hearing communities, we have not identified any specific opportunities to promote good relations through the operation of this pilot.   

Consultation

Tell us about who you have talked to about your proposals, either internally or externally and who you have formally or informally consulted, to help you decide if the policy needs further equality investigation?

In November 2021 the Northern Ireland Assembly Commission approved a pilot for the provision of live sign language interpretation of Question Time to the Executive Office Ministers to the end of the mandate.  The pilot was to be in both British Sign Language (BSL) and Irish Sign Language (ISL) and to be made available on the Assembly Website.  The pilot ran in parallel to the manual subtitling of Question Time to the Executive Office that was available on playback after Question Time rather than in real time.  

An informal advisory group composed of both individuals from the hearing and deaf community representing Deaf Community advocacy groups (local and national), individuals from the Deaf Community, sign language interpreters, and a child of deaf adult (CODA) was established to provide a conduit of information flow and learning back and forth between the advisory group into the deaf community itself and the Assembly representatives interacting with it.  The work of this group was invaluable in providing input on many aspects of the pilot. 

In April – May 2022, a review of the pilot was undertaken with representatives from the informal advisory group, the interpreters and internally with the various Assembly business areas involved in the delivery of the pilot.  The main finding is that the pilot was well received by the deaf community, who have now indicated a desire for more interpretation services. 

Research has indicated that all other parliaments in the UK and Ireland routinely provide sign language interpretation for Prime Minister’s / Leader’s Question Time and a varying range of other matters ranging from Ministerial Statements, matters of national importance, major debates such as on the Budget etc.  There are variations in the amount of live and retrospective signing, as well as signing of Committee Business. 

In November 2022, SMT considered the review of the pilot and agreed that the pilot should be continued, with a signing of Plenary Business, normally Question Time, relevant Committee Business and other certain special events such as the first sittings in a new mandate, tributes, VIP addresses to the Assembly etc.

Disability Duties

Consider whether the policy:

a) Discourages disabled people from participating in public life and fails to promote positive attitudes towards disabled people.

The policy does not discourage disabled people from participating in public life.  The policy promotes a positive attitude towards those from the Deaf and hard of hearing community

b) Provides an opportunity to better positive attitudes towards disabled people or encourages their participation in public life.

The policy provides an opportunity to better positive attitudes for the Deaf and hard of hearing community and encourages their participation in public life

Additional considerations

Multiple identities

Generally speaking, people can fall into more than one Section 75 category.  Taking this into consideration, are there any potential impacts of the policy/decision on people with multiple identities? 

(For example; disabled minority ethnic people; disabled women; young Protestant men).

Provide details of data of the impact of the policy on people with multiple identities.  Specify relevant Section 75 categories concerned.

As with any community, those from the Deaf and hard of hearing communities will have a variety of identities. However,  none of these  are deemed likely to suffer  a negative impact as a result of this policy.  

Part 3 Screening decision

Through screening, an assessment is made of the likely impacts; either major, minor or none, of the policy on equality of opportunity and/or good relations for the relevant categories.  Completion of screening should lead to one of the following three outcomes:

• Screened out’ i.e. the likely impact is none and no further action is required.
• ‘Screened out’ with mitigation i.e. the likely impact is minor and measures will be taken to mitigate the impact or an alternative policy will be proposed.
• ‘Screened in’ for an equality impact assessment (EQIA) i.e. the likely impact is major and the policy will now be subject to an EQIA.

The option slected is:

'Screened out' with mitigation i.e. the likely impact is minor and measures will be taken to mitigate the impact or an alternative policy will be proposed.

If the decision is not to conduct an equality impact assessment, please provide details of the reasons.

N/A

If the decision is not to conduct an equality impact assessment, but the policy has minor equality impacts, please provide details of the reasons for this decision and of any proposed mitigating measures or proposed alternative policy.

This is a policy directly designed to have a positive impact for the Deaf and hard of hearing community.  There is one minor issue to be considered – that of a possibility that people from minority racial backgrounds may need signing in languages other than BSL and ISL.  A watching brief will be kept on this issue.

If the decision is to subject the policy to an equality impact assessment, please provide details of the reasons.

N/A

Timetabling and prioritising for EQIA

Complete this section only if your business area/directorate plans to conduct two or more EQIAs.

Factors to be considered in timetabling and prioritising policies for equality impact assessment:

If the policy has been ‘screened in’ for equality impact assessment, then please answer the following questions to determine its priority for timetabling the equality impact assessment.

On a scale of 1-3, with 1 being the lowest priority and 3 being the highest, assess the policy in terms of its priority for equality impact assessment.

Note: The Total Rating Score should be used to prioritise the policy in rank order with other policies screened in for equality impact assessment.

Is the policy affected by timetables established by other relevant public authorities?

N/A

Part 4 Monitoring

Effective monitoring will help identify any future adverse impact arising from the policy which may lead the Commission to conduct an equality impact assessment, as well as help with future planning and policy development.

The ECNI recommends that where a policy has been amended or an alternative policy introduced, the public authority should monitor more broadly for adverse impact. See ECNI Monitoring Guidance for use by Public Authorities (July 2007) pages 9-10, paragraphs 2.13 – 2.20

Please detail how you will monitor the effect of the policy?

It is anticipated that an informal advisory group, similar to that created for the pilot, will be established to help monitor the effects of the policy in the community most impacted – the Deaf and hard of hearing community.

What data is required in the future to ensure effective monitoring of the policy?

Feedback from the Deaf and Hard of hearing community.

Part 5 Data Protection

If applicable, has legal advice been given due consideration?

N/A

Has due consideration been given to information security in relation to this policy?

Yes

Part 6 Approval and authorisation

Screened by: Stella McArdle

Position/Job Title: Assembly Clerk

Date: Thursday, 17 November 2022

Approved by: Frank Geddis, Clerk Assistant

The policy lead should sign and date the policy under the ‘screened by’ heading. It should then be countersigned by an approver.   The Approver should be the senior manager responsible for the policy which would normally be Head of Business. In instances where a screening decision concludes that an EQIA is required then the screening form should be countersigned by the Director instead of the Head of Business.

There are of course a range of issues which may fall within the scope of being novel, contentious or politically sensitive and could only be taken forward following consultation with the Assembly Commission.   Where policy screening highlights novel, contentious or politically sensitive issues, once approved by the Director, the screening form should be forwarded to the Clerk/Chief Executive for review, prior to proceeding to SMT and the Assembly Commission.

A copy of the completed screening form, related policy and any other relevant associated documentation should be forwarded to the Equality Manager. 

ADDITIONAL INFORMATION TO INFORM THE ANNUAL PROGRESS REPORT TO THE EQUALITY COMMISSION

1. Please provide details of any measures taken to enhance the level of engagement with individuals and representative groups.

N/A

2. In developing this policy/decision were any changes made as a result of equality issues raised during:

a) pre-consultation/engagement; 

b) formal consultation;

c) the screening process; and/or

d) monitoring/research findings.

If so, please provide a brief summary including how the issue was identified, what changes were made, and what will be the expected outcomes/impacts for those affected.

N/A

3. Does this policy/decision include any measure(s) to improve access to services including the provision of information in accessible formats?  If so, please provide a short summary.

N/A

Appendix 1 Screening Questions

Introduction

In making a decision as to whether or not there is a need to carry out an equality impact assessment, you should consider your answers to the questions above.

In addition, the screening questions above further assist you in assessing your policy and must be completed. Some of these questions require you to assess the level of impact of the proposed policy on “equality of opportunity” and “good relations”. The scale used when assessing this impact is either “None”, “Minor” or “Major”. The following paragraphs set out what each of these terms mean.

If your conclusion is none in respect of all of the Section 75 equality of opportunity and/or good relations categories, then you may decide to screen the policy out.  If a policy is ‘screened out’ as having no relevance to equality of opportunity or good relations, you should give details of the reasons for the decision taken.

If your conclusion is major in respect of one or more of the Section 75 equality of opportunity and/or good relations categories, then consideration should be given to subjecting the policy to the equality impact assessment procedure.

If your conclusion is minor in respect of one or more of the Section 75 equality categories and/or good relations categories, then consideration should still be given to proceeding with an equality impact assessment, or to:

• measures to mitigate the adverse impact; or
• the introduction of an alternative policy to better promote equality of opportunity and/or good relations.

In favour of a ‘major’ impact

a) The policy is significant in terms of its strategic importance;

b) Potential equality impacts are unknown, because, for example, there is insufficient data upon which to make an assessment or because they are complex, and it would be appropriate to conduct an equality impact assessment in order to better assess them;

c) Potential equality and/or good relations impacts are likely to be adverse or are likely to be experienced disproportionately by groups of people including those who are marginalised or disadvantaged;

d) Further assessment offers a valuable way to examine the evidence and develop recommendations in respect of a policy about which there are concerns amongst affected individuals and representative groups, for example in respect of multiple identities;

e) The policy is likely to be challenged by way of judicial review;

f) The policy is significant in terms of expenditure.

In favour of ‘minor’ impact

a) The policy is not unlawfully discriminatory and any residual potential impacts on people are judged to be negligible;

b) The policy, or certain proposals within it, are potentially unlawfully discriminatory, but this possibility can readily and easily be eliminated by making appropriate changes to the policy or by adopting appropriate mitigating measures;

c) Any asymmetrical equality impacts caused by the policy are intentional because they are specifically designed to promote equality of opportunity for particular groups of disadvantaged people;

d) By amending the policy there are better opportunities to better promote equality of opportunity and/or good relations.

In favour of none

a) The policy has no relevance to equality of opportunity or good relations.

b) The policy is purely technical in nature and will have no bearing in terms of its likely impact on equality of opportunity or good relations for people within the equality and good relations categories.