At Thrive we are committed to providing equality of opportunity for everyone we provide services to and to the people we employ and do business with.
This framework sets out the actions we will take to ensure we comply with our statutory duties under relevant Equalities legislation and Codes of Practice.
Obligations under the Equality Act 2010
The Equality Act 2010 (“the Equality Act”) aims to make society fairer for everyone. It brings together and strengthens previous equality legislation, The Act was introduced to make equality law simpler to understand and easier to follow.
The Equality Act protects people who come from different groups and communities under the following ‘protected characteristics’:
- Gender (sex)
- Pregnancy and maternity
- Marriage and civil partnership
- Religion or belief*
- Gender re-assignment
- Sexual orientation.*
*See compliance with Data protection legislation
Whilst Thrive is not defined as a “public authority” under the Equality Act, Thrive would be carrying out a public function when managing social housing (including allocation, termination and eviction) and therefore must also comply with the general Public Sector Equality Duty.
Thrive must have due regard to the following three issues when reviewing existing policies and services or when planning new ones. This also applies to staff development, training and management. It is not sufficient to consider these issues after a decision has already been taken.
- Eliminate unlawful discrimination, harassment, victimisation and other conduct prohibited by the Equality Act 2010.
- Advance equality of opportunity between persons who share a relevant protected characteristic and those who do not share it.
- Foster good relations between persons who share a relevant protected characteristic and those who do not share it.
This means it is not enough to simply avoid discriminating – Thrive is required to take a more proactive approach.
We can advance equality of opportunity by:
- removing or minimising disadvantages suffered by people with protected characteristics where those disadvantages are connected to that characteristic;
- taking steps to meet the needs of people who share a relevant protected characteristic that are different from people who do not have that characteristic; and
- encouraging those who share a relevant protected characteristic to participate in public life or in any other activity where participation is disproportionately low.
We can foster good relations by:
- tackling prejudice and promoting understanding.
Where Thrive is exercising a non-public function under the Equality Act, i.e. a non-housing function, the Public Sector Equality Duty would not apply.
Compliance with Data Protection Legislation
The new General Data Protection Regulation (‘GDPR’) and Data Protection Act 2018 provide tighter control around processing ‘special categories’ of personal data. Some special categories are also ‘protected characteristics’ under the Equality Act, highlighted with an * above, but the lists are not the same.
Thrive can lawfully process data about individuals’ race, religious beliefs, health and sexual orientation, which are all ‘special categories’ of personal data, for the purposes of reporting on equality of treatment and opportunity amongst diverse people, with a view to promoting or maintaining that equality. Thrive can process race information about senior people at Thrive, either currently in post or when identifying new potential senior people, as long as appropriate policies are in place and followed. The policies should explain how the GDPR Principles will be complied with when personal data is processed for Equality and Diversity purposes, and give an indication of how long the personal data being used for that purpose is likely to be retained.
The following forms of discrimination are prohibited and are unlawful:
Direct Discrimination (including by association/perception) – where someone is treated less favourably than another person because of a protected characteristic. For example, rejecting a job applicant because of their religious views or because they might be gay. This may also apply to a person who does not have the protected characteristic themselves but is linked to or associated with someone who does. It may also apply where a person is wrongly thought to have a protected characteristic or is treated as if they do.
Indirect Discrimination – When there is a provision, criterion or practice that applies to everyone but disadvantages people who share a particular protected characteristic more than others and is not justified.
Harassment including by association – this includes sexual harassment and other unwanted conduct related to a protected characteristic, which has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them.
Victimisation – occurs when someone is treated badly because they have done something in relation to the Equality Act, such as making or supporting a complaint or raising a grievance about discrimination, or the service provider believes they have done so.
Disability discrimination – this includes direct and indirect discrimination, any unjustified less favourable treatments because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability
Statements and Objectives
Thrive is committed to treating people fairly and as equals working in a principled and responsible way to provide a good place to work, quality homes and consistent services.
We will do this through the following four objectives split by the organisation and customers:
A) Leading by example, creating a culture of equality and diversity that informs our business decisions.
B) Creating a skilled, reliable and resilient team, dedicated to quality and consistency.
C) Delivering fair and accessible services, collecting the right information from customers to measure this.
D) Valuing our partners in the areas where we work to create safe, secure affordable homes for customers.
We will create an Equality, Diversity and Inclusion Steering Group to promote this ED&I Framework, be responsible for delivering the actions and monitor and report back on progress. The terms of reference for this group is at Appendix B, will be made up of staff from across the organisation and will involve our CEP and wider customers in delivering the two customer objectives.
Actions to Achieve our Four Equality Objectives
A) Leading by example, creating a culture of equality and diversity that informs our business decisions
- Publish our Equality Framework, all language, imagery, policies, procedure and publicity are inclusive and representative of our diverse customer group.
- Communicate a zero-tolerance approach to discriminatory attitudes or practices from staff, partners, contractors, suppliers, customers.
- Create an Equality and Diversity Steering Group to promote our E&D framework, report and monitor delivery of these actions
- Engage with groups representing people with protected characteristics.
- Ensure that partners and contractors delivering services on our behalf adopt our principles and approach to equalities.
- Collect relevant information about our customers so that we can understand more about their needs and preferences for service delivery and to help us identify barriers or potential barriers to accessing our services, against the 2018 baseline (appendix A)
- Act on customer feedback when shaping our services, including information received through our complaints process and regular customers surveys.
B) Creating a skilled, reliable and resilient team, dedicated to quality and consistency.
- Operate fair recruitment and employment practices. Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability.
- Review our employment practices and pay to ensure they are fair and foster an effective and diverse workforce against the 2018 baseline. (Appendix B)
- Maximise the potential of employees and encouraging people to be the best they can be through individual training and development plans.
- Train our staff so they understand our approach to equality and how this translates into equal and fair services for customers.
- Give staff the opportunity to shape and influence the delivery of fair and accessible services.
- Create an environment that promotes dignity and respect to all, in which individual differences and the contributions of all our employees are recognised and valued.
C) Delivering fair and accessible services, collecting the right information from customers to measure this
- Ensure flexibility in service delivery so they are fair and accessible.
- Ensure that all our policies and strategies reflect our approach to equality and have a consistent approach to completing Equality Impact Assessments.
- Offer a range of ways for customers to contact us and make sure that our offices are accessible to people with limited mobility and different sensory abilities.
- Make the most of technology to provide 24/7 access to services and to help enable easy access to online service for people with different needs.
- Communicate with our staff and customers on how we will use customer profiling to review our services.
- Work with the CEP to empower customers to monitor and review our services for equality and diversity.
- Provide appropriate information in accessible formats to our customers about our performance on equality and diversity.
D) Valuing our partners in the areas where we work to create safe, secure affordable homes for customers
- Identify our local partners in each of the areas we operate, building links with diverse and representative groups to strengthen our relationship within the areas we work and ensure our services are representative and diverse.
- Work with our partners to advance equality of opportunity and foster good relations between different community groups
- Investigate allegations and work with our partners to eliminate discrimination, tackle harassment, hate incidents and hate crime and domestic violence.
Progress on the actions above will be monitored by the Equality, Diversity and Inclusion Steering Group every six weeks and report annually to EMT, CEP and Remuneration and Governance Committee. This Framework will be reviewed in five years’ time or sooner should there be legislative changes or if highlighted during the monitoring of the framework.
Approved: January 2019