I wish I could say we saw this coming. In 2018, Advance HE started working with a group of senior managers, planners and equality leads from a set of Scottish universities and colleges, in a Scottish Funding Council (SFC) supported project to develop an approach to embed equality and diversity in strategic planning and decision making.
Our intention was to share practice from across HE and FE and the public sector more broadly, and then identify the common principles that underpinned good practice. However, we quickly realised that despite equality impact assessment (EIA) being a legal requirement in Scotland for any policy or strategy, there were very few examples of EIA applied systematically and effectively in strategic decision making.
The project group felt that our standard practices in the sector, the operational EIA processes that institutions were familiar with, were less helpful in strategic decision making and quickly changed tack. We needed a new approach to EIA that would conceptualise equality as a core component of strategic decision making, and a clear, simple process to embed this in institutional planning.
We drew on aspects of Scottish practice we felt worked well, both from universities and colleges but also government and charities. We looked at other impact assessment processes with a track record of informing and influencing strategic decisions, such as strategic environmental assessments.
Just as we were finalising the guidance with SFC and getting ready to share it with the sector, Covid-19 introduced a new set of strategic challenges: rapid shifts to online delivery and assessment, changes to admissions policy and practice, the future reoccupation of campus, and the response to financial challenges, including cost saving and restructuring, which will all create risks and negative impacts for equality groups. Whilst all protected characteristic groups will experience some negative impact, some, e.g. disabled people, BAME and international staff and students, and female staff will bear the most negative consequences if key issues are not addressed.
We now have an urgent need to identify the most affected groups in our institutions, make evidence based, equitable decisions, and ensure the required rapid change doesn’t exacerbate existing inequalities.
These considerations have been central to some of Advance HE’s early work with the sector in supporting planning for next year, such as in the Socially Distanced Campus and Education project. They also speak to the key challenges identified in our SFC project and addressed by the guidance. An effective SEIA, particularly one taken under rapid or agile circumstances, will start with answers to the following questions:
- Do you know what your core EDI priorities are?
- Do you have a proportionate, evidence-based approach to understanding the impact your plans for next year will have on different groups?
- For your highest priorities or groups likely to experience the greatest negative impact, do you have a mechanisms to efficiently and quickly consult with stakeholders?
- Can you see opportunities in these changes to improve equality of access, address attainment gaps etc.
Benefits of strategic EIA
A robust SEIA model offers a clear institutional framework, providing the following benefits:
- Articulate and hold institutional equality priorities through rapid strategic change
- Evidencing commitment and action to institutional values and ethos to staff and students
- Identifying and mitigating legal, financial and reputational risk
- Improved efficiency and effectiveness through aligning and mainstreaming related institutional commitments, e.g. developing a coordinated approach to race equality, integrating responses to the EHRC enquiry on racial harassment in HE, work towards the Race Equality Charter (REC), impact on BAME staff and students of Covid-19, and institutional commitments and action on ‘Black Lives Matter’
- Supporting a proportionate approach and response to a range of different and complex equality priorities, negative impacts and opportunities
- Identifying, integrating and mainstreaming good practices in delivering fair and equitable access and experiences in education and employment.
The suggested model for strategic EIA shown in Fig 1 prompts institutions to consider:
- Stage one: Start the SEIA as early as possible, scope and identify equality priorities using existing institutional commitments, legal/regulatory requirements, including the public sector equality duty (PSED) and consultation with stakeholders
- Stage two: Understand, assess and judge high level risks and opportunities to identify desired outcomes and impacts, clearly articulating any changes or mitigating action required, drawing on relevant data, evidence and stakeholder views
- Stage three: Strategic intentions and direction are effectively cascaded and mainstreamed through the institution and coordinated and mapped thorough operational plans and policies
- Stage four: Ensure clear structures for accountability and governance in relation to the SEIA process and actions.
Guidance and resources on EIA
Guidance on conducting a strategic EIA is available on Advance HE’s website. There is a full set of resources here to support different roles and experience levels within institutions. We have made them practical, and in fact, these are the same resources we’re currently using internally to undertake a SEIA as we develop Advance HE’s organisational strategy.
A rapid response to Covid-19
If you’re thinking about applying SEIA to your institution’s response to Covid-19, consider using the following tools:
- Start with the more detailed SEIA process map, and think about how an SEIA would fit with the strategic decisions you’ve taken to date, as well as the planning work you’re heading into, and how you might embed the SEIA process within that
- Then look at the good practice checklist, which will help you understand what developmental or preparatory activity you might still need to undertake. Key actions include:
- Having clearly defined institutional EDI priorities
- Collating high level evidence in relation to potential negative impacts on equality groups or to your institutional priorities from your Covid response, including identifying any meaningful gaps in data and evidence
- Planning for focussed consultation and how to involve key staff, students and stakeholders in priority areas, such as addressing key data and evidence gaps, assessing and mitigating significant risks, or understanding impacts to the delivery of organisational EDI priorities
- Some decisions have already been taken in planning for 20/21, but post-hoc assessment against EDI priorities, evidence of differential impact and focussed consultation is still essential. Taking mitigating action now or reviewing decisions is in keeping with the principle of agile planning that is resilient to change, and responsiveness to new evidence and information
- Finally, for current planning, adapt and use our simple SEIA template, which has been designed to help institutions efficiently embed practice in the short term.