Norfolk Probation Area

Disability Equality Scheme 2006-2009

Contents 1 2 2.1 2.2 2.3 2.4 2.5 3 3.1 3.2 4 4.1 4.2 5 6 6.1 6.2 6.3 6.4 6.5 6.6 6.7 Introduction by Martin Graham, Chief Officer General introduction of the Disability Equality Scheme Aims and Objectives Values and Commitment to Diversity The NPA Disability Equality Scheme Involvement of Disabled People Implementing the Scheme Duties under the Disability Discrimination Act General Duties Specific Duties Key challenges on disability equality National Challenges Local Challenges Outcomes of NPA Disability Equality Scheme Process and arrangements for delivering our specific duties Accessibility Plan Impact Assessment of Policies Leadership Involvement and Community Engagement Communication and Information Services for Offenders and Victims Employment and Training

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Annex A: NPA functions and policies and their relevance to the General Duty Annex B: NPA Disability Action Plan Annex C: NPA Framework for Developing Policy, Strategy, Processes and Guidelines and Equality Impact Assessment template Annex D: Legislation Annex E: Comments form Annex F: Glossary

If you require this document in another format please contact: Rowena Kerr, Diversity Manager Tel: (01603) 220107 Email: rowena.kerr@norfolk.probation.gsi.gov.uk

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Introduction Norfolk Probation Board welcomes the implementation of the Disability Discrimination Act, amended in 2005, and the accompanying new Disability Equality Duty for all public bodies.

We are in the business of providing a public service as well as being a public service employer. Therefore, the integration of equality and diversity values are paramount in everything we do. Our Diversity Policy states clearly our vision and aims and our Business Plan translates these stated aims into measurable actions and outcomes.

Disability is one of the social identity areas that has long been enshrined in our diversity policy and our employment policies as well as in the assessment and monitoring arrangements for offender management. The introduction of the new Disability Equality Duty therefore presents a timely opportunity for us to continue to develop in this area, thus ensuring that all our staff and service users are not discriminated on the grounds of their disability. I also strongly believe that we should aim to go beyond the requirements of the legislation and demonstrate best practice in championing the rights of disabled people in our community, particularly through our community engagement agenda.

I believe that the Norfolk Probation Board Disability Equality Scheme represents an integrated approach with measurable outcomes in achieving our ambitions as well as fulfilling our duty under the new legislation.

Martin Graham Chief Officer

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2 2.1

General Introduction to the Disability Equality Scheme Aims and objectives of Norfolk Probation Area: Norfolk Probation Area (NPA) is one of 42 local areas which make up the National Probation Service (NPS) within the National Offender Management Service (NOMS). The aims of the NPS are: • Protecting the public • Reducing re-offending • Ensuring the proper punishment of offenders in the community • Ensuring offenders’ awareness of the effects of crime on the victims of crime and the public • Rehabilitation of offenders The establishment of NOMS provides a new context for work with offenders which includes: • A focus on offender management with a single offender manager responsible for assessing need, selecting and sequencing interventions; • The use of commissioning to separate the identification of need from the delivery of services; • The use of contestability to challenge existing providers to demonstrate they can continue to provide the best value in terms of both cost and quality whilst meeting the diverse needs of service users. The NPA Business Plan for 2006/07 sets out the following key priorities: • Continue to contribute to the development of NOMS • Working collaboratively with other criminal justice agencies to protect the public from harm • Working with other criminal justice agencies and local Crime and Disorder Reduction Partnerships in England and Community Safety Partnerships in Wales to develop a new service delivery model • Working with other criminal justice agencies, Judges and Magistrates to reduce re-offending by consolidating the implementation of the 2003 Criminal Justice Act with a particular focus on the new sentence of Custody Plus which will be introduced in November 2006 • Working with the Prison Service and other key agencies to ensure compliance with legislation to embed quality and diversity in the NPS in its work with offenders and in its HR polices. Norfolk Probation Board also recognises its priorities and actions need to be delivered via a skilled, committed and diverse workforce, providing a range of high quality and effective services to offenders, victims and the wider criminal justice system, on behalf of the people of Norfolk. Priority 6 of the NPA Business Plan 2006/07 is about embedding equality and diversity into practice. The actions for 2006/07 are:

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• Produce a Disability Equality Scheme as required by the Disability Discrimination Act 2005 • Ensure that procedures and practices are compliant with all equalities legislations • Implement a strategy for work with women offenders • Establish processes to monitor performance against key targets by race, gender, age, faith, sexual orientation and disability Therefore, the development of a Disability Equality Scheme is an important strategy to underpin the above ambitions and objectives. 2.2 Values and Commitment to Diversity The NPA’s values and commitment to diversity are stated in our Diversity Policy as follows: Norfolk Probation Board commits itself to equal service for all staff, offenders, victims of crime and our communities regardless of social identity. Equal service means fair, accessible, inclusive, appropriate and effective provisions in employment and service delivery practices. Social identity includes age, class, disability, ethnicity, faith, gender and sexual orientation. We acknowledge that disabled people have diverse social identities and therefore in promoting our new Disability Equality Duty we are delivering it in unison with our duties under the current equality legislations for race, age, gender and sexual orientation through a strategic approach. Norfolk Probation Board also recognises its leadership role in promoting diversity and equality of opportunities in all the relevant strands. It is therefore committed to implementing organisational structures, policies and services that fulfil not only our legal duties but also redress inequalities and yield positive changes. The concept of leadership will emanate from board level through diverse representation including the recruitment of co-opted members from the community through to the structure of Diversity Champions across NPA. Our strategic focus for diversity therefore cover the key areas of: • Leadership Commitment • Workforce diversity and Equality • Equal and Accessible services • Community engagement and communication, and • Legislative duties

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The NPA Disability Equality Scheme The Norfolk Probation Area’s Disability Equality Scheme (DES) sets out our commitments, arrangements and actions in fulfilling our duty to promote disability equality in response to the Disability Discrimination Act 2005 (DDA) which now places a duty on all public authorities to have due regard to the needs of disabled people when carrying out their functions. Our DES 6

explains how the service will make sure it promotes equality of opportunity for disabled people and challenges discrimination against them and sets out our strategic actions to facilitate the removal of barriers faced by disabled people. Under the DDA, a disabled person is legally defined as someone with a physical or mental impairment, which has a substantial and long-term adverse effect on his/her ability to carry out normal day-to-day activities. However, the overarching principle of the DES is working within the Social Model of disability which challenges the prejudice, attitudinal and institutional discrimination in the treatment of disabled people in society. This is a shift away from the medical model which views disabled people as the problem where service providers and employers are not able to meet their needs. 2.4 Involvement of disabled people In developing its Disability Equality Scheme, NPA has involved both its disabled staff and disabled service users. It has also had the involvement of an external disability group Norfolk Coalition of Disabled People. Details of the involvement are contained in Section 3 of this Scheme. Accountability and Implementation of the Scheme The Scheme will be implemented by the NPA Board, Chief Officer and his senior management team and officers via the delegated structure of the Equality Working Group which is a committee of the NPA Board. The Equality Working Group oversees the implementation and progress of the DES and its Action Plan by receiving regular reports from the Diversity Manager. The Working Group also presents an annual report of the outcomes of the NPA Diversity Action Plan, which will incorporate the Disability Action Plan, to the Board. This will ensure that strategic issues are embedded in the NPA Business Plan. 2.6 This first Disability Equality Scheme is open to the community and voluntary partners as well as other statutory agencies, particularly criminal justice agencies, to comment. We welcome in particular the contribution of local disability organisations in ensuring that the actions we have set are relevant and will count towards the elimination of discrimination and harassment of service users and employees. A comment form is attached in Annex E. Duties under the Disability Discrimination Act The General Duty Norfolk Probation Board being a public authority covered by the newly amended Disability Discrimination Act 2005 has a duty to have due regard to the following areas in carrying out our functions: • Promote equality of opportunity between disabled persons and other persons • Eliminate discrimination that is unlawful under the Act • Eliminate harassment of disabled persons that is related to their disabilities • Promote positive attitudes towards disabled persons

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3 3.1

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• Encourage participation by disabled persons in public life; and • Take steps to take account of disabled persons’ disabilities, even where that involves treating disabled persons more favourably than other persons The NPA Board recognises that the overarching goal of the general duty is to promote equality of opportunity and to provide a framework to support public authorities to tackle discrimination and its causes in a proactive way by mainstreaming disability equality into all functions, policies, decisions and activities. The involvement of disabled staff, service users and disability organisations is a key mechanism to implementing the general duty so that services are inclusive – fit for purpose and accessible to disabled people. In addition, other important mechanisms to enable us to fulfil our general duty are: • Undertaking impact assessment of policies and functions • Gathering and analysing evidence of gaps and barriers to equality of opportunity for disabled people • Public reporting of our Scheme and involvement • Leadership commitment • Training for staff • Partnership involvement and procurement of services 3.2 Specific Duties In addition to the General Duty, we are also required to fulfil specific duties under the Act to produce a Disability Equality Scheme which outlines how we intend to fulfil our general and specific duties, in particular, having regard to: • The involvement of disabled people • Arrangements for impact assessment • Arrangements for gathering information in relation to employment and service users • A Disability Equality Action Plan • Publishing the Disability Equality Scheme 3.2.1 Involvement of Disabled People In developing the Scheme, NPA has involved both its disabled staff and disabled service users. It has also had the involvement of an external disability group – Norfolk Coalition for Disabled People. Involvement of disabled staff: The development of this Scheme has involved working with disabled staff in the region. We held a regional event in June 2006 for disabled staff to share their experiences on a number of key issues including employment; staff support networks, workplace culture and assistive technology and other

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reasonable adjustments. Some of the concerns expressed by disabled staff include the following: • Lack of awareness of support network • Good policies but need follow-through • Lack of confidence among some managers in dealing with disabled staff • Frustration of using assistive technology • Resentment among colleagues of ‘special treatment’ • Lack of consultation over reasonable adjustments The number of disabled people employed in NPA in 2006 is 15. This represents about 4.6% of the overall staff profile. Disabled staff in Norfolk will continue to be involved in the implementation of the Action Plan and a number of them have volunteered to facilitate some staff focus groups as part of the implementation strategy. Disabled Service User Involvement: We also carried out a survey with about 300 offenders about their experience in accessing our services and provisions. Respondents provided information about their disability and whether or not they have experienced any barriers in accessing our services and in fulfilling their probation requirements. We also invited suggestions as to how improvements can be made. This was a large scale survey and a full report is available. The findings from this survey will be disseminated with managers and staff. Feedback will be provided to offenders as to what changes we are making/have made following the survey. Key issues from the survey will also be included in the DES Action Plan. Of the 263 offenders who took part in the survey, a considerable proportion described themselves as having a disability. This varies from 6.8% in one locality (Great Yarmouth) to 26% reported at Thetford. The average for the county is 18.5%. The range of conditions/impairments given was also wide ranging. These findings will have important implications for the way we deliver our services. It is recognised that some disabled people would be reluctant to disclose their disability particularly among the more vulnerable offenders. Therefore, our engagement programme with disabled staff and offenders will need to approach individuals in a climate of trust, sensitivity and empathy. We will also continue to evaluate the various methods of engagement such as focus groups, or one to one interviews using reasonable adjustments where appropriate to ensure access and participation. Local disability organisation Involvement: We have made contact with Norfolk Coalition for Disabled People (NCODP) which consists of 25 groups of disabled people throughout the county of Norfolk. The aim of NCODP is to make sure all disabled people were aware of their rights and to campaign for improvements in service provision. NCODP embraces the social model of disability and adopts a user-led, rightsbased approach to service provision. NCODP has provided an advisory role 9

in the development of this Scheme and this link will continue through a more formalised structure of involvement such as via the Equality Working Group and the Impact Assessment Group. This action is incorporated in the Scheme Action Plan. NPA will continue to develop and improve on its involvement strategy with disabled staff, disabled service users and the wider disability community by obtaining feedback, evaluating the different methods of engagement, and by making reasonable adjustments to ensure wider access and participation. 3.2.2 The NPA arrangements for impact assessment All of NPA’s policies and procedures are subject to impact assessment, using the template issued by the National Probation Directorate. Section 6 contains full details of NPA’s method of impact assessment and the guidelines for policy developers in preparing documents for impact assessment. Our equality impact assessment (EIA) covers the equality areas of age, disability, ethnicity, gender, faith, sexual orientation and class and has been in operation since the implementation of the Race Relations Amendment Act in 2003. 3.2.3 The NPA Disability Equality Action Plan As part of our Specific Duty, NPA has also developed a Disability Action Plan. (Annex B of this Scheme). The actions set out in the Action Plan are to be achieved within the first year of this Scheme and contain SMART objectives. The ongoing monitoring of progress of the Action Plan will be via: • Monthly reviews by the ACO (Diversity) and Diversity Manager during supervision meetings • NPA’s Equality Working Group which meets bi-monthly • Annual report of Diversity Action Plan to the Equality Working Group and the Board. This will include a full review and report of the Disability Equality Scheme. • Issues arising from staff involvement and user involvement as well as external disability organisations will be incorporated in the annual report and will inform the Action Plan for the second year. It is envisaged that this will be a continuous process of engagement, involvement and decision making to ensure that the actions are relevant and prioritised according to the needs of users and the requirements of the General and Specific Duties under the DDA. 3.2.4 Arrangements for gathering information in relation to employment The Human Resource Department maintains a staff monitoring database by age, disability, ethnicity and gender. Information is collected at preemployment stage and updated throughout the period of employment of all NPA staff. The Human Resource Manager produces an annual report to the Workforce Working Group of staff diversity profiles relating to the following areas:

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• Grade • Job application and appointment • Career Progression • Grievance procedures • Disciplinary procedures • Harassment cases • Performance appraisal procedures • Training and development opportunities • Dismissals and other reasons for leaving The purpose of the employment monitoring is to detect any pattern of discrimination by age, disability, ethnicity or gender. Where there are issues arising, strategies will be devised to eliminate such discriminatory practices. In addition to quantitative data collected via the above mechanisms, NPA also conducts staff surveys and focus groups where ‘softer’ data is obtained. This will provide insight into the cultural issues about the organisation and will be disseminated via the management structure of SMT and the Board. 3.2.5 Arrangements for gathering information in relation to service users The National Probation Directorate has issued guidance on the collection of data relating to disabled service users. This guidance was adopted by NPA and a Practice Note (PC31) was issued to all staff. Disability monitoring will be undertaken of all offenders at pre-sentence report stage and at induction for offenders released on licence. The data is entered on the offender database and any reasonable adjustments required are also recorded. The purpose of the above monitoring is to ensure that we are addressing the needs of disabled offenders in completing their sentence compliance plans. In addition, we will continue to conduct offender surveys and focus groups to obtain the views and experiences of offenders on disability and other diversity issues to enable us to improve our services and provisions. We also intend to publish feedback to service users on service improvements that they have suggested. 3.2.6 Publishing the Scheme The NPA Scheme will be published by 4 December 2006 via the following means: Internal communication: • Staff Intranet • A printed copy at every office/locality • All Board Members and Coopted Members from the community External communication: • Partnership agencies • Other criminal justice agencies – via the Criminal Justice on-line website

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• Local disability organisations such as Norfolk Coalition for Disabled People and Norwich Mind • Other local voluntary organisations eg. NNREC (Norfolk and Norwich Race Equality Council)

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Key Challenges on Disability Equality National Challenges The key challenge in the implementation of the Scheme is to ensure that in a climate of rapid reforms to the service and in particular, contestability, that the values, good practice and commitment on diversity are not compromised and that the requirements of the Disability Equality Duty will be stringently applied in the service specifications in future contestability processes. Local Challenges Although NPA is able to demonstrate some good practice in meeting the requirements of the General Duty, we need to ensure we have the necessary resources to build on our work and meet other challenges. One key challenge is to integrate the principles of inclusive design and the social model in carrying out our functions and duties so that disabled staff receive the appropriate support to do their jobs and that disabled service users have access to our facilities and services. Examples of good practice Employment: • NPA has been awarded the two tick Disability mark in its employment practice. Our application pack is available in various formats. • Disability is one of the monitoring areas for staffing profiles. • Our staff induction diversity training addresses disability discrimination – in terms of legislation and service provision. Service provision: • NPA is a partner of INTRAN which provides interpreting, translation and communication support to service users who have communication needs. Deaf Connexions is one of the providers within the INTRAN partnership. The services provided by INTRAN have enabled us to meet the needs of service users. • Disability of offenders is monitored and entered on the offender database and where reasonable adjustments are required these are also recorded so that ongoing monitoring of their effectiveness can be carried out. • As part of the Offender Satisfaction Survey, we also undertook an access audit for the different locations where offenders attend. The findings are published within the Report of the Survey and will inform an NPA Accessibility Plan. 12

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Partnership: • NPA procures its services from a number of partnership agencies such as Norfolk Association for the Rehabilitation of Offenders, Citizens Advice Bureau. We routinely share good practice on diversity with our partner agencies to ensure that our services are fair and accessible. For example, we held a partnership day to share issues on equality monitoring in September 2006 where we highlighted the new Disability Discrimination Act and identified ways of more collaborative ways of working in promoting equality issues for service users. Community Engagement: • We are committed to engage with a diverse range of community groups and organisations and have in the last year recruited a coopted member from Norwich Mind who serves on the Equality Working Group and the Community Panel which assesses Unpaid Work projects to benefit diverse community groups and voluntary organisations. • Through the process of this Scheme, we have made contact with a key disability organisation in Norfolk and will continue to build this partnership to enable closer involvement in the implementation of the Scheme. Equality Impact Assessment: • The NPA equality impact assessment follows the guidelines from NPD and has been commented by the Audit Commission as good practice in the Diversity Audit in 2005. Disability Hate Crime • NPA launched the True Vision third party reporting system in September 2006 as part of our overall strategy in tackling Hate Crime which includes physical attack, harassment and bullying on the grounds of age, race, belief, domestic violence, sexual orientation and disability. Diversity Champions have received training to act as the local contact for Hate Crime reporting. This service is available to both staff and service users. The information pack includes useful national and local support groups, personal safety tips and what to do if you are a victim or a witness. 4.3 Challenges to be addressed: In this first year of the Disability Equality Scheme, it is also important that we address the following key issues: o Training for all staff on the new Disability Equality Duty o Ensure that Diversity Champions receive training on the Disability Equality Duty and be able to provide advice and support on disability issues to their teams and colleagues

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o Establishing links with disability organisations and the most appropriate consultation mechanisms with disabled staff and service users o Publishing the Disability Equality Scheme to partnership agencies and other external organisations and voluntary groups o Establishing clear monitoring procedures in the area of employment as well as service delivery and a system for review o Developing an NPA accessibility plan o Ensuring that disabled staff have access to disabled staff support network either through the National Disabled Staff Support Network or via the regional group o Developing a transport strategy to tackle the rural nature of the county to enable attendance of appointments for service users at NPA offices o Develop policy and guidance on Unpaid Work in respect of disabled offenders

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Outcomes of the NPA Disability Equality Scheme In implementing the NPA Disability Equality Scheme, we expect that the following outcomes will be delivered. They are summarised under the five strategic areas for diversity: Leadership: • There is clear commitment at leadership level to disability equality which is demonstrated through the vision and values of NPA as well as through organisational structure and resources – for example, Diversity Champions, disabled staff support network. • Managers and team leaders to demonstrate diversity competency in team management and offender management, assessed via the performance appraisal system • The Equality Working Group has representation on disability issues, particularly at coopted member level Workforce Diversity and Equality: • Recruitment procedures are accessible by disabled applicants • Disabled staff have access to support networks • Harassment Support Workers are trained to provide support for disabled staff • NPD positive action programme ‘ Accelerate’ is targeted at disabled staff • Diversity competency framework to include disability issues • Support for disabled staff who use Assistive Technology is available Equal and Accessible Services: 14

• An accessibility plan developed for all NPA premises • NPA’s performance areas are monitored by disability • Action plan produced following the Offender Satisfaction Survey in September 2006 to address the disability issues highlighted in the report • Audit of victim support work in terms of disability issues undertaken and actions planned • A timetable for the assessment of functions and policies published for the first year of the Scheme • A procurement policy that addresses disability issues to ensure compliance in contract specification and delivery on the part of providers. • Data collection on disability monitoring improved from existing performance. Community Engagement and Communication: • A strategy for engagement and communication with local disability organisations developed • A range of communication methods established which are accessible by disabled staff and disabled service users • NPA community engagement programmes to have included organisations and voluntary groups for disabled people Legislative Duties: • All staff and managers to have received training or briefing on the Disability Equality Duty • All Board Members including coopted members to have received training or briefing on the Disability Equality Duty • NPA procedures for equality impact assessment include disability equality and comply with DDA 2005 • New Disability Equality Scheme published

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Delivering our Specific Duties Accessibility Plan The National Probation Directorate commissioned a full audit of all NPA premises in 2004, to determine whether its services and buildings were reasonably accessible to disabled people. The audit revealed that there are access issues relating to all of our premises. A full report and recommendations is available on request. This will form the basis of our Accessibility Plan. Although a new build is due for completion in 2008 for the Norwich base which has been designed and being built to DDA compliance standard, the accessibility plan needs to address the access needs for the premises at Kings Lynn, Thetford and Great Yarmouth. Commissioning and meeting the expense involved in the implementation of the Accessibility Plan rests with the NPD through its estates contract.

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However, NPA will need to contribute to the accessibility plan by devising strategies for making bids to get the implementation underway. 6.2 Impact Assessment of Policies It is important to embed disability equality in all of NPA’s functions and policies so that the concept of inclusive design is translated into practice. The process of equality impact assessment is therefore an important mechanism to ensure that there is equality of opportunity for all service users and staff and that there is no adverse impact as a result on disabled staff and service users. NPA’s arrangements are: • All policy development and review are subject to the NPA’s Equality Impact Assessment (EIA) process, using the Framework for Developing Policy, Strategy, Processes and Guidelines and the Equality Impact Assessment template (Annex C). All policies are presented to the Equality Impact Assessment Group which comprises officers and coopted members representing a diverse range of equality and diversity issues from the community. Following the EIA process, the policies are presented to the main Equality Working Group for final scrutiny and then presented to the Board for final approval. The Equality Working Group maintains a prioritised list of functions and policies and a timetable for the regular review of these functions and policies. The prioritisation of functions and policies is guided by national priorities and are assessed in terms of their relevance to the General Disability Equality Duty. NPA is committed to undertake the statutory 3-year disability equality review of our functions and policies and new policies. All NPA policy documents show date of origination of policy and review dates as well as the name of the policy developer. All policies which have been impact assessed are recorded in the minutes of the Equality Working Group and available on the intranet. All policies are also subject to ongoing monitoring via regular reports to the relevant working groups. For example, employment reports which include information (broken down by age, disability, gender and ethnicity) on recruitment, sickness absences, grievance/disciplinary cases are presented to the Workforce Working Group.

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NPA will publish the outcomes of the assessment of its functions and policies and results of consultations and monitoring using the following channels and media: Internal communication: • Minutes of Equality Working Group • Quarterly report of the Diversity Action Plan • Staff Briefing • Staff Focus Group • NPA intranet site • Diversity Champions • Staff Support Groups • Focus Groups with offenders • Newsletter such as Respect which is circulated within the Eastern Area HMP Prison Service External communication: • Partnership agencies • Other criminal justice agencies – via the Criminal Justice on-line website • Local disability organisations such as Norfolk Coalition for Disabled People and Norwich Mind • Other local voluntary organisations eg. NNREC (Norfolk and Norwich Race Equality Council) 6.3 Leadership Accountability: Norfolk Probation Board has overall responsibility for reviewing and managing performance of actions arising from this Disability Equality Scheme. The lead on diversity is held by a designated Assistant Chief Officer who: • Reports to the Senior Management Team (SMT) on diversity issues and our progress on the Diversity Action Plan (including the Disability Action Plan) • Attends the Equality Impact Assessment Group, the Equality Working Group and Workforce Working Group • Attends events aimed at minority staff (such as the LGBT Regional Event) • Attends the Regional Diversity Management Group • Supervises the Diversity Manager Additionally, leadership on diversity is demonstrated through: • the Local Criminal Justice Board Diversity Action Group is chaired by our Chief Officer • sharing of good practice by the Diversity Manager with other Probation Areas across the Region • a system of Diversity Champions who are recruited and trained from staff groups and who act as local contacts for field teams on diversity matters

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• a system of Harassment Support Workers who are recruited and trained in supporting staff on harassment issues • new staff induction week begins with an introduction on Diversity and ends on day 5 with a one-day Diversity Training The role of Chief Officer and SMT: The Chief Officer and SMT ensure that objectives relating to disability equality duty and diversity are mainstreamed with the NPA Business Plan by setting specific objectives and performance targets so that all unit plans have action plans that reflect these objectives and targets. 6.4 Involvement and Community Engagement Staff involvement: Disabled staff at NPA have been involved in the development of this Disability Equality Scheme at a regional event held in June 2006. Staff have commented on the value of working together and found it a positive experience. A report was produced and disseminated with disabled staff across NPA. Issues arising from the consultation are being addressed via the Disability Action Plan. Staff involvement will continue via the following strategies: • involvement of disabled staff at disability briefing and training events • Staff focus groups on disability issues • Participation at the National Disabled Staff Support Network (NDSSN) and its regional activities Community Engagement: Through the development of this Disability Equality Scheme, we have the contribution from the Norfolk Coalition for Disabled People (NCODP) which consists of 25 groups of disability organisations throughout the county of Norfolk. We also have a coopted member on the Equality Working Group from Norwich Mind. Norfolk Probation Board is a part of the local Criminal Justice Board and therefore works in close partnership with all criminal justice agencies in promoting wider public access to its services through a community engagement strategy which includes hosting and participating in community events in building public confidence. We will continue to develop and improve on our involvement strategy with external disability organisations so that we are better able to make referrals on behalf of our service users and form long-term partnership in enabling wider access and participation. In the first year of our Scheme, we will aim to achieve the following: • Develop a community engagement strategy • Make contact with more disability organisations locally

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• Improve the representation of disability organisations on our community engagement programmes such as LCCS (Local Crimes, Community Sentences) 6.5 Communication and Information NPA has developed a set of Accessibility Guidelines which give staff information and guidance on communicating with diverse groups and techniques in meeting a range of communication needs. A copy of the Accessibility Guidelines is available on request. NPA has a partnership agreement with INTRAN which provides for the interpreting and translation needs on our behalf including the provision of Braille, BSL and other communication needs. All staff are expected to attend the INTRAN training course on using interpreters and working with people with hearing or sight impairments. Information on disability and diversity issues is communicated to staff by the following methods: • Weekly Bulletin – an email bulletin issued by the Communications Officer with links to relevant websites and attachments • Diversity Champions receive information from the Diversity Manager and disseminate with staff at team meetings or post on Diversity notice boards in area teams • Diversity events are publicised to all staff and all managers who are expected to encourage staff to attend (such as the LBGT regional event) • Focus groups on specific issues are held from time to time to provide opportunities for open communication External Communication: NPA has an external communication strategy. The Chief Officer and members of the SMT make use of the local media to communicate on issues that have public interest or concern. We also have links with regional and local community and organisations and publish vacancies and other events through their newsletter and other media. A Summary of outcomes of Disability Equality Scheme will be disseminated with local disability organisations and community groups on an annual basis via community engagement events and other community media such as newsletter/internet sites aimed at disabled people. Public access: Norfolk Probation Board’s Chair and the Chief Officer will decide how best to make information about their policies and services accessible to the public, having regard to the Disability Equality Duty and in accordance with the Data Protection Act and Freedom of Information Act. 6.6 Services for offenders and victims

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NPA is committed to provide equal service for all offenders, victims of crime and our communities regardless of social identity. Equal service means fair, accessible, inclusive, appropriate and effective provisions. We recognise that certain groups are discriminated on the grounds of age, ethnicity, disability, faith, gender and sexual orientation. We are committed to uphold our Disability Equality Duty to eliminate discrimination and promote equality of opportunity among our service users. We will embed the principle of inclusive design and the Social Model of disability in all our procedures and practice by: • Undertaking disability monitoring – NPA has adopted the practice guidance issued by NPD to undertake disability monitoring of offenders. A local practice note (PC31) has been issued to all staff on the procedures to follow. A monitoring form has been devised which offender managers will use with offenders to obtain the following information: o the nature of any disability within the meaning of the DDA o the type of impairment, and o any adjustments required The information is recorded on the offender database and to be reviewed by the offender manager to ensure that offender needs continue to be met. • Dealing with all offenders with sensitivity and empathy, particularly in ascertaining their disability and needs • Assessing arrangements for Unpaid Work Programmes to consider reasonable adjustments and health and safety issues to widen participation of disabled offenders • Reviewing arrangements for Accredited Programmes to consider reasonable adjustments to widen participation of disabled offenders • Continuing to assess the hostel regime to ensure that the needs of disabled offenders are met and that reasonable adjustments are considered with the involvement of offenders • Undertaking disability monitoring of victims to ensure that access and communication needs are met in the case of disabled victims • Providing clear and jargon free information to victims so that they are clear about disclosure of information and protection that can be provided by the police • Making liaisons and referrals with voluntary agencies and community organisations as additional sources of support for offenders and victims, including local disability support groups • Making use of the Hate Crime third party reporting system which NPA has adopted for hate crime reporting relating to age, disability, faith, race and domestic abuse and violence • Working in close partnership with the CJB Witness Care Unit to ensure that victims receive the maximum support

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Procured functions: The Assistant Chief Officer for Interventions has a responsibility for procurement. NPA will be developing a policy on procurement which will specify its General and Specific Duty under the Disability Discrimination Act 2005 and will establish procedures for assessing service providers in meeting these duties. The Diversity Manager attends the review meetings of procured services to ensure that the disability equality duty is delivered by partnership agencies. 6.7 Employment and Training Norfolk Probation Board is committed to a policy of equal opportunity for all its staff, regardless of age, ethnic origin, religious belief, gender, disability and sexual orientation or any other irrelevant factor. Recruitment and progression are entirely based on competency assessed against criteria for the job. Positive action will be taken to support individuals to develop their full potential wherever possible. Norfolk Probation Board will also participate in any positive action programme implemented by NPD. Norfolk Probation Board is, therefore, committed to meeting its statutory employment duties under the Disability Discrimination Act 2005 to ensure equality of opportunity for disabled job applicants in the recruitment process and that reasonable adjustments are considered and implemented for disabled staff to enable them to carry out their roles and have access to NPA facilities and provisions. NPA will also ensure that disabled staff have equal opportunities in career progression and development, supported by positive action where appropriate. Employment Monitoring: In order to meet the employment duties, Norfolk Probation Board will monitor disability by: • The number of staff in post and their grades • Applicants for jobs, and the outcome of such recruitment exercises. • The results of progression/promotion exercises, and where applicable, assessment centres. Norfolk Probation Board will also set disability targets for recruitment and progression. • The numbers who make use of grievance procedures, and the outcome of those procedures. • The numbers facing disciplinary action, and the outcomes of that action. • The number of cases brought to the attention of the Harassment Support Network. • The results of performance appraisal procedures, ensuring that they are effectively monitored. • Access to and take-up of training opportunities. • Dismissals and other reasons for leaving.

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Norfolk Probation Board already has in place exit interview procedures. Results of above arrangements are reported to the Workforce Working Group on a quarterly basis. In addition, Norfolk Probation Board will regularly audit its employment policies against the Disability Rights Commission (DRC) Code of Practice and NPD guidance and take and record the actions taken to address areas of weakness shown to exist. Norfolk Probation Board’s Chair and Chief Officer will ensure that the outcomes of monitoring processes are analysed to check that the systems that have been put in place do not have an adverse and differential impact on disabled people. If the analysis suggests such an impact exists then further investigations will be undertaken and recommendations made will be taken forward by the Board. Training: Norfolk Probation Board’s commitment is to ensure that all staff working in Norfolk Probation Area are trained to be fully competent in all key diversity areas including disability in discharging their duties. The aim is to have a learning organisation where the development and/or improvement of knowledge, skills, experiences and awareness are integrated into day-to-day practices and behaviours. Identification of training needs and opportunities for personal and team development is carried out via the staff appraisal and performance management processes. Norfolk Probation Board produces an annual Diversity Training Plan which is incorporated into its general Training Plan. All staff are required to attend a one-day diversity training course. For new staff, this takes place in the induction week which is the first week of commencement of employment. The contents of the training course include legislation and issues relating to disability. In addition to the one-day diversity course, there are other diversity courses which target at specific roles such as Probation Services Officers, Diversity Champions. Specific training and briefing on the new Disability Equality Duty have been scheduled for board members, managers and operational staff. All training courses are subject to an evaluation process where course participants give feedback on a range of issues including equality practice and accessibility issues. This process ensures that training programmes are relevant, adequate, monitored and reviewed.

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Annex A: Functions and policies and their relevance to disability equality Offender Management Offender Assessment: • OASys • Court reports • Supervision plans • Parole assessments • Curfew assessments • Risk management plans • Sentence plans Case Management: • Induction • Completions • Breach procedures • Supervision Centres Work with prisoners pre-release: • Assessments undertaken by seconded staff • Accredited programmes in prison • Other work undertaken by seconded staff • Contact and work with prisoners undertaken by community based staff Work with prisoners post-release: • Young Offender Supervision • Life licences • Other post-release supervision Management of risk: • Risk assessment • Child protection • Potentially dangerous people • Sex offenders • Multi-Agency Public Protection Panel • Domestic abuse • Serious incident reports Interventions Approved Premises: • Management of John Boag House • Accredited Programmes • Psychometric testing • Unpaid Work • Drug Treatment and Testing Order/Drug Rehabilitation Requirement completions • Community supervision • Work with victims • Bail and bail information Offender accommodation: • John Boag House approved premises 23

• Partnership funded accommodation providers Partnerships: • Basic skills • Employment, training and education • Substance misuse • Mental health • Finance and benefit advice

Support Services Human Resource Management: • Recruitment, selection and retention • Conditions of service • Leave and time-off • Supervision and appraisal / performance management • Training and staff development • Mobility • Secondments • Flexible working • Staff care • Reward schemes • Staff well being • Discipline, grievance and capability • Sickness management • Harassment • Whistle blowing • Staff survey • Exit interviews Finance Property and contracts Communication: • Internal and external communication • Public relations and community engagement Information and information technology Health and safety Complaints procedure Diversity Performance and planning

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Annex B: Disability Equality Action Plan (January to December 2007) Disability Equality Objective 1: Leadership Commitment Relevance to General Duty of Disability Equality Lead Responsibility Organisational Risk Cross Reference with Timescale for actions under Objective 1 Actions 1.1 Demonstrate leadership commitment at all levels to disability equality by: • Supporting and recognising the work of the Diversity Champions • Ensuring disabled staff have access to support networks • Providing training to Harassment Support workers on Disability Discrimination Act 2005 1.2 Managers and team leaders demonstrate diversity competency in team management and offender management

High ACO (Support Services) High Diversity Action Plan December 2007 Lead Responsibility Diversity Manager

Outcome Measures Increased visibility and recognition of Diversity Champions. Disabled staff have information about support networks and are encouraged to participate by managers. Increased awareness among Harassment Support workers on disability discrimination in discharging their role, evidenced in evaluation questionnaire. Increased awareness among leaders at all levels on diversity issues, as evidenced in supervision, appraisals and performance reports. Observable difference in team ethos and settings, as evidenced in staff surveys and focus groups. Improved representation on Equality Working Group on disability issues

ACOs/SPOs/OSMs

1.3 Recruit representatives from disability organisations and communities as co-opted members on the Equality Working Group

Diversity Manager

Disability Equality Objective 2: Workforce Diversity and Equality Relevance to General Duty of Disability Equality Lead Responsibility Organisational Risk Cross Reference with Timescale for actions under Objective 2

High ACO (Support Services) High Diversity Action Plan December 2007

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Actions 2.1 Set local target and devise recruitment procedures that reach disabled communities to continue to develop a skilled and diverse workforce. 2.2 Monitor the harassment support scheme to identify any pattern of harassment or bullying based on specific social identity groups including disabled staff

Outcome Measures Local target for disability recruitment met or showing improvement.

Lead Responsibility HR Manager

2.3 Participate in future programmes of ‘Accelerate’ by NPD that target disabled staff into senior management 2.4 Develop a diversity competency framework (including disability issues) to be integrated into job descriptions and person specification and used for the purposes of assessments, performance management, training and development. 2.5 Ensure provision and support for disabled staff who use Assistive Technology

Reduction of grievance and disciplinary cases relating to harassment. Staff perception of a safer and more harmonious working environment, as evidenced in staff surveys and focus groups. Improved representation at SMT level of disabled people. Increased diversity awareness and competency among staff at all levels of roles and responsibilities, as evidenced in supervision, appraisals and performance reports. Improved performance and morale among disabled staff, as evidenced in staff consultation/focus groups.

HR Manager /Diversity Manager

HR Manager

HR Manager / Diversity Manager

IT Manager/ Occupational Health Manager

Disability Equality Objective 3: Equal and accessible services Relevance to General Duty of Disability Equality Lead Responsibility Organisational Risk Cross Reference with Timescale for actions under Objective 3 Actions 3.1 Improve on disability monitoring and ensure that data collected is disseminated regularly to assess if reasonable adjustments are implemented and effective. 3.2 Develop action plan arising from Offender Satisfaction Survey in September 2006 to address disability

High ACO (Support Services) High Diversity Action Plan December 2007 Outcome Measures Percentage of disability monitoring improved from 70% missing data. Improved satisfaction among disabled service users, assessed via focus groups, complaints or satisfaction survey. An integrated approach to addressing disability issues with performance outcomes that are Lead Responsibility All ACOs

Diversity Manager

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issues highlighted in the report 3.3 Undertake an audit of victim support work on disability issues and devise actions to address any barriers to services 3.4 Publish a timetable for the assessment of functions and policies for the purpose of the Disability Equality Scheme 3.5 Develop a policy on procurement identifying processes for the assessment of contractors in meeting the Disability Equality Duty.

3.6 Develop Accessibility Plan for NPA based on report by NPD of premises audit and strategies for bidding with NOMS for implementation of plan 3.7 Develop a policy and guidance on Policy and guidance implemented. Unpaid Work in respect of disabled offenders 3.8 Improve diversity practice in partnership working including court procedures to ensure that staff and offenders are not discriminated on the ground of disability. Disability Equality Objective 4: Community engagement and communication Relevance to General Duty of Disability Equality Lead Responsibility Organisational Risk Cross Reference with Timescale for actions under Objective 4 Actions 4.1 Develop a strategy for engagement and communication with local disability organisations. 4.2 Ensure that our communication methods are accessible by disabled staff and disabled service users, using information based on consultations Court procedures reflect diversity practice following equality impact assessment.

measurable. Increased awareness of disability issues in victim support work and an action plan with performance outcomes that are measurable. An integrated approach to the assessment of functions and demonstrates compliance with the Disability Equality Duty. A policy that meets the requirements of the new Duty and ensures that disabled service users have access to high quality services and developed with stakeholder involvement. Accessibility Plan and strategies developed and agreed with NOMS.

Diversity Manager

Diversity Manager

ACO (Interventions)/ Diversity Manager

Diversity Manager and Health and Safety Manager Unpaid Work Manager and Diversity Manager Diversity Manager/ACOs

High ACO (Support Services) High Diversity Action Plan December 2007 Outcome Measures A consultation mechanism that meets the requirements of the Disability Equality Duty. Improved channels of communication with disabled staff and service users, based on follow-up feedback from staff and Lead Responsibility HR Manager

Diversity Manager

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undertaken as part of this Scheme. 4.3 Ensure that our community engagement programmes include organisations and voluntary groups for disability.

service users. Improvement involvement of disability organisations in NPA business and policy making processes, based on number of contacts made and programme participation.

Diversity Manager / Communication Officer

Disability Equality Objective 5: Legislative duties Relevance to General Duty of Disability Equality Lead Responsibility Organisational Risk Cross Reference with Timescale for actions under Objective 5 Actions 5.1 Ensure that all staff and managers and board members receive training / briefing on the Disability Discrimination Act and the Disability Equality Duty. 5.2 Undertake audit of NPA procedures for equality impact assessment and ensure that disability equality issues are assessed and comply with legislation. 5.3 Publish Disability Equality Scheme and receive feedback from partners and stakeholder organisations

High ACO (Support Services) High Diversity Action Plan December 2007 Outcome Measures Improved awareness at all levels of the organisation of Disability Equality Duty, based on evaluation of training programmes. NPA procedures for equality impact assessment include disability equality issues and are compliant with legislation. NPA’s commitment and actions are shared with the community to inform review of DES and Action Plan. Lead Responsibility Diversity Manager/ Training Manager Diversity Manager

Diversity Manager

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Annex C NPA’s Equality Impact Assessment Process All of NPA’s functions and policies are subject to the process of equality impact assessment. The process is undertaken via the Equality Working Group. A timetable for the assessment of function and policies is drawn up by the Board Secretary and scheduled into the meetings of the Equality Working Group and the Equality Impact Assessment Group. For all policy development and review, policy owners must follow the NPA Framework for Developing Policy, Strategy, Processes and Guidelines. This framework tool acts as a screening process with questions which enable the policy writer to consider the research and evidence (national and local) that are relevant to the proposed policy. The framework also asks for information on stakeholder interest, consultation groups, critical success factors, evaluation method, and potential risks. Policy developers are expected to conduct the necessary consultations with key stakeholder groups to inform the development of the policy. The Framework Document also identifies an implementation plan, evaluation methods, and communication strategy for the policy as well as resource implications such as training needs. In the light of the new Disability Equality Duty, the Framework document will be reviewed to ensure that the concept of inclusive design and the social model are embedded. The Framework template gives guidance for policy developers and contains a diversity impact assessment section. Policy developers are asked to complete this before the policy reaches the Equality Impact Assessment Group which includes 6 co-opted members recruited from local Black and minority ethnic organisations. One of the action areas is to recruit co-opted members from the local disability organisations so that disability issues are fully represented in the assessment process. The co-opted members contribute to the Equality Impact Assessment process by scrutinising the consultation process and monitoring undertaken by the policy developer, and to offer comments and suggestions to ensure that no minority groups will be discriminated against or disadvantaged by the policy. The equality impact assessment process is conducted in the Equality Impact Assessment Sub-Group using the assessment tool – NPA Equality Impact Assessment (Annex D). Any adverse impact or issues arising from this process are communicated to the policy developer for the policy to be revised to address the issues identified. Then the revised policy is represented to the Equality Working Group at a future date before its formal approval by the Board. The Equality Working Group meets bi-monthly preceded by the Equality Impact Assessment Group and acts as the final scrutiny of all NPA policies and functions for equality implications before its final presentation to the Board.

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Norfolk Probation Area Equality Impact Assessment template 1 2 3 4a Is this a new policy? Is this a new function? If this is an existing policy show date of last review Is the policy/function relevant to the Public Duty to promote good race relations : Is the policy/function relevant to the Public Duty to promote disability equality? Is the policy/function relevant to the Public Duty to promote gender equality? Is the policy/function relevant to the promotion of good practice in other diversity fields Yes/No Yes/No

Yes/No

4b

Yes/No

4c

Yes/No

4d

If the answer to 4a, 4b, 4c and 4d is No – stop here! If Yes to either – please proceed with Assessment 5 Please state below how the Based on information on the local following groups might be communities, the diversity profiles, affected any specific groups who are likely to be unfairly or adversely affected by this policy due to: Race/nationality

Gender

Sexual Orientation

Belief

Disability – i. Physical ii. iii. Age learning difficulties sensory

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Class

Mental health

Any other groups identified? (eg. Unemployed, homeless, literacy level, having caring responsibility, people living in rural areas, refugees or asylum seekers)

6

Measuring impact of relevant functions and policies: Is the function/policy subject to equality monitoring? How is the data collected/disseminated? Where will it be discussed? Has the policy developer consulted with any groups or sought information from them? Other diversity observations: Language Format Does the policy follow NPA’s Accessibility Guidelines? Yes/No

Yes/No

7

8

Changes proposed for the policy developer:

Yes/no

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Annex D: Legislation The Disability Discrimination Act (1995) has been amended by the Disability Discrimination Act 2005 which now places a General Duty on all public authorities to have due regard to the needs of disabled people when carrying out their functions: • Promote equality of opportunity between disabled persons and other persons • Eliminate discrimination that is unlawful under the Act • Eliminate harassment of disabled persons that is related to their disabilities • Promote positive attitudes towards disabled persons • Encourage participation by disabled persons in public life; and • Take steps to take account of disabled persons’ disabilities, even where that involves treating disabled persons more favourably than other persons The overarching goal of the General Duty is to promote equality of opportunity and to provide a framework to support public authorities to tackle discrimination and its causes in a proactive way by mainstreaming disability equality into all functions, policies, decisions and activities. The involvement of disabled staff, service users and disability organisations is a key mechanism to implementing the general duty so that services are inclusive – fit for purpose and accessible to disabled people. In addition, other important mechanisms to enable us in fulfilling our general duty are: • Undertaking impact assessment of policies and functions • Gathering and analysing evidence of gaps and barriers to equality of opportunity for disabled people • Public reporting of our Scheme and involvement • Leadership commitment • Training for staff • Partnership involvement and procurement In addition to the general duty, we are also required to fulfil specific duties under the Act to produce a Disability Equality Scheme. The Scheme will outline our arrangements in fulfilling our general and specific duties. The NPA Disability Equality Scheme will include the following: • The way in which disabled people have been involved in the development of the Scheme • The NPA arrangements for impact assessment

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• The NPA Disability Equality Action Plan • The NPA arrangements for gathering information in relation to employment and the delivery of our services • The process for reviewing the effectiveness of our action plan The NPA Scheme will be published by 4 December 2006.

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Annex E: Comment form
Please answer the following questions by putting a circle on your responses:

Having read the Norfolk Probation Board’s Disability Equality Scheme, I feel that I have a better understanding of the requirements of the Disability Equality Duty. Strongly agree Agree Unsure Disagree Strongly disagree Please briefly explain your answer:

1

Having read the Norfolk Probation Board’s Disability Equality Scheme, I feel that I have a good idea of what Norfolk Probation Area is trying to achieve. Strongly agree Agree Unsure Disagree Strongly disagree Please briefly explain your answer:

2

The actions set out in the Action Plan are adequate in meeting our Disability Equality Duty. Strongly agree Agree Unsure Disagree Strongly disagree Please briefly explain your answer:

3

4

If you have further comments about our Disability Equality Scheme, please list here and continue overleaf if required.

5

If you are interested to be involved in our community engagement programmes or equality impact assessment work please give your name and contact details below: Name: Organisation: Contact details:

Thank you for completing this feedback form. We value your views and contribution.

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Annex F: Glossary ACO CO DDA DES DRC EIA EWG HR NPA NPD NPS NOMS OASys RES SMART SPO OSM Assistant Chief Officer Chief Officer Disability Discrimination Act Disability Equality Scheme Disability Rights Commission Equality Impact Assessment Equality Working Group Human Resources Norfolk Probation Area National Probation Directorate National Probation Service National Offender Management Service Offender Assessment System Race Equality Scheme Specific, measurable, achievable, results oriented and time specific Senior Probation Officer Operation Support Manager

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Race Equality Scheme 2005 – 2008 Norfolk Probation Area

1

Introduction The document is a review of Norfolk Probation Area’s (NPA) progress in its 2002-2005 Race Equality Scheme, including an assessment of the arrangements for carrying out the race impact assessment of its functions and policies relevant to the General Duty under the Race Relations (Amendment) Act 2000. It follows the template as provided by the National Probation Directorate (NPD) and consists of two parts: Section A gives an overview of our progress in implementing our Race Equality Scheme, our Race Equality Impact Assessment process and a summary of actions arising from the review. Section B outlines the arrangements for the Race Equality Scheme (2005-08) under the key areas of: Equality Impact Assessment, Leadership, Consultation and Community Engagement, Communication and Information, Services for Offenders, Services for Victims, Employment, Training, as well as considerations from national and local issues. The final part of the document identifies a list of actions arising from each of the above areas. These actions have be formulated into NPA’s Diversity Action Plan which is the composite strategic plan for diversity for Norfolk - The NPA Diversity Action Plan sets out our key performance targets and expected outcomes and should therefore be referred to in conjunction with this document.

2

Section A: Overview of progress in the 2002-05 scheme, including progress made on race impact assessment of functions and policies 1. A brief review of progress in implementing priorities in the 2002-05 Scheme and its overall impact

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Section A: Overview of progress in the 2002-05 scheme, including progress made on race impact assessment of functions and policies • The NPA Race Equality Scheme follows a national framework issued by the NPS which sets out clearly the guiding principles and rationale for meeting the General Duty. There is clear leadership commitment to meeting the General Duty at the NPA. The strategic responsibility for diversity is held at ACO level with all managers holding responsibility for the promotion and application of policies and procedures within their brief. In addition, the Board demonstrated its commitment by the appointment of a Diversity Manager despite the constraint on budgetary provision in 2004. This leadership commitment is also translated at organisational level through the establishment of a working group (The Equality Working Group comprising Board members, managers, diversity champions, union representatives) which has a diversity remit and oversees the overall monitoring of the NPA Diversity Action Plan as well as the process of equality impact assessment. The Board also approved the appointment of up to 6 co-opted members to be recruited from Black and minority ethnic communities to serve on the Equality Working Group. The key objective is to widen engagement with BME communities in the business of the NPA at policy making level and to assist the Working Group with its equality impact assessment of policies and functions. In 2005, three members from local Black and minority ethnic communities were recruited and co-opted to the working group. In 2006, 6 members from Black and minority ethnic communities were recruited to serve on the Equality Working Group. In 2007, The structure for Equality Impact Assessment was delegated to an Equality Impact Assessment Group comprising the coopted members and officers and invited stakeholders. (updated September 2007). The NPA Business Plan for 2005/06 links its key objectives to the Race Equality Scheme to ensure that race equality issues are mainstreamed in the business process. The Chief Officer of NPA is currently the Chair for the Norfolk Criminal Justice Board Race Action Group which works to deliver a race action plan. One of the key achievements in 2004 was a community information event for Black and minority ethnic community groups hosted by the Norfolk CJB in partnership with a number of voluntary partner organisations, as part of its community engagement strategy. The event received very positive feedback from participants and enabled the Norfolk CJB to develop its own BME community data base. The Race Action Group also seeks to develop more collaborative ways of working among all the criminal justice agencies in promoting race equality. NPA has also responded to the HMIP ‘Towards Race Equality’ and its follow up inspection by incorporating the recommendations into its race equality action plan and subsequently into its Diversity Action Plan. The issues arising from this review have been incorporated into the NPA Diversity Action Plan and reflected in Section B of this document. 4

• •

Section A: Overview of progress in the 2002-05 scheme, including progress made on race impact assessment of functions and policies • NPA made a Service Level Agreement with the Norfolk and Norwich Race Equality Council (NNREC) in 2004 with objectives to develop wider community engagement, to promote good race relations and to develop joint partnership working to raise the profile of NPA within the local community. Eg the Board sponsored Black History Month in 2005 and has placed job vacancies in the NNREC publication “Black & White”. In terms of external scrutiny of the Race Equality Scheme, we took part in a local RES review conducted by the NNREC in 2003/4 and received our report in 2004. The Chief Officer, the ACO (with Diversity remit) and the Diversity Manager met with the Director of NNREC and discussed the findings and identified key action points to address issues raised.

5

2. The Race Equality Impact Assessment Process • • • • The Equality Working Group maintains a prioritised list of functions and policies and a timetable for the regular review of these functions and policies. The prioritisation of functions and policies is guided by national priorities and are assessed in terms of their relevance to the General Statutory Duty. All NPA policy documents show date of origination of policy and review dates as well as the name of the policy developer. All policy developers are required to use and follow the NPA Policy Development Framework which contains a Diversity Impact Assessment template. The Framework Document prompts the policy developer to identify all stakeholders and the consultation method. It is expected that policy developers will have undertaken consultations with the identified key stakeholders and impact-assessed the policy. The policy is then presented to the Equality Impact Assessment Group (since 2007) comprising Black and minority ethnic co-opted members, officers and other invited stakeholders. Any changes/comments are then passed back to the policy developer/owner for amendments. All the changes are recorded on the Equality Impact Assessment document. The amended policy is then presented to the Equality Working Group for its final diversity impact assessment and approval before approval by the Board. Feedback on consultations will be published via Staff Briefing, staff focus groups, community engagement events, local Black and minority ethnic publications such as the NNREC's ‘Black & White’, and the newsletter of MENTER (Minority Ethnic Network in the Eastern Region). It has been noted in the recommendations of the Diversity Audit undertaken by the Audit Commission in 2005 that we need to consider the issue of consultation with service users – offenders and victims in particular. This will be taken forward as a specific action point in this RES. A list of policies (Annex 1) which have been impact-assessed during the period of the first RES is maintained by the Board Secretary.

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3. A Summary of actions arising from the Review of the 2002-05 Race Equality Scheme • Assess the functions of NPA relevant to the General Duty in promoting race equality by identifying specific race and diversity issues in the unit plans. • Establish a structured consultation mechanism with Black and minority ethnic communities in undertaking equality impact assessment of NPA’s functions and policies, and work collaboratively with other criminal justice agencies on large-scale consultations with BME communities and organisations where there are common themes. • Establish a system of communication with BME communities and organisations to publish/communicate results of consultations and the Race Equality Scheme. • Analyse race and ethnic monitoring data collected in respect of offenders and scrutinise for any pattern of discrimination or barriers to services. • Establish a structured approach to consulting with offenders and victims and ensure feedback is given to them on how their views have influenced policies and practice. • Ensure that partnership agencies involved in the delivery of services on our behalf are consistent in undertaking race and ethnic monitoring and adopt the Census 2001 16+1 categories. • Ensure public access to information and services by implementing the community engagement programme and NPA’s external communications strategy. In addition, we will make use of our link with the NNREC through the Service Level Agreement in delivering this objective. • Integrate diversity training into the mainstream training programme. • Develop a diversity competency framework and link this to assessments, performance management and training and development. • Analyse data on staff promotions and present regular reports to the Equality Working Group.

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Section B: 2005-08 Race Equality Scheme 1. Race Impact Assessment: Policies and functions to be assessed 2005-08 • • • • • The Equality Working Group maintains a prioritised list of functions and policies and a timetable for the regular review of these functions and policies. The prioritisation of functions and policies is guided by national priorities and are assessed in terms of their relevance to the General Statutory Duty. NPA is committed to undertake the statutory 3-year race equality review of our functions and policies and new policies. All NPA policy documents show date of origination of policy and review dates as well as the name of the policy developer. The NPA’s impact assessment process begins at the policy formulation stage. Our Framework for Developing Policy, Strategy, Processes and Guidelines acts as a screening process with questions which enable the policy writer to consider the research and evidence that are relevant to the proposed policy. The framework also asks for information on stakeholder interest, consultation groups, critical success factors, evaluation method, and potential risks. Policy developers are expected to conduct the necessary consultations with key stakeholder groups to inform the development of the policy. The Framework Document also identifies an implementation/deployment plan, evaluation methods, and communication strategy for the policy as well as resource implications such as training needs. The Framework template gives guidance for policy developers and contains a diversity impact assessment section. Policy developers are asked to complete this before the policy reaches the Equality Working Group which now includes 6 co-opted members recruited from local Black and minority ethnic organisations. The role of the BME co-opted members is to contribute to the Race and Diversity Impact Assessment process by scrutinising the consultation process and monitoring undertaken by the policy developer, and to offer comments and suggestions to ensure that no groups will be discriminated against or disadvantaged by the policy. When the policy reaches the formal impact assessment stage - ie the Equality Impact Assessment Group, the process of diversity impact assessment is applied using the assessment tool – NPA Diversity Impact Assessment. Any adverse impact or issues arising from this process are communicated to the policy developer for the policy to be revised to address the issues identified. Then the revised policy is presented to the Equality Working Group at a future date before its formal approval by the Board. (Updated September 2007).

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2. Race Impact Assessment - Action points and expected outcomes • Monitor the whole process of Race and Diversity Impact Assessment to ensure that there are tangible and positive outcomes in compliance with the General Duty. • Monitor the effectiveness of the co-opted members and ensure they are fully integrated into the work of the Board and contributing to NPA’s community engagement agenda. • Maintain a list of the policies and functions for the purpose of Race and Diversity Impact Assessment to ensure that all policies and functions relevant to the General Duty are subject to the impact assessment process. (Annex 2 – list of policies to be assessed in 2007/08 as agreed by the Equality Working Group). •

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3. Leadership

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There is clear leadership commitment by the NPA to meeting the General Duty. The strategic responsibility for diversity is held at ACO level with all managers holding responsibility for the promotion and application of policies and procedures within their brief. In addition, the Board demonstrated its commitment by the appointment of a Diversity Manager despite the constraint on budgetary provision in 2004. This leadership commitment is also translated at organisational level through the establishment of a working group (The Equality Working Group comprising Board members, managers, union representatives) which has a diversity remit and oversees the process of equality impact assessment. The Board has also approved the appointment of up to 6 co-opted members be recruited from Black and minority ethnic communities to serve on the Equality Working Group. The key objective is to widen engagement with BME communities in the business of the NPA at policy-making level and to assist the Working Group with its equality impact assessment of policies and functions. In January 2006, further co-opted members were recruited increasing the capacity from 3 to 6 members. All new co-opted members received a day’s induction training about the work of the Probation Board and their role as a coopted member. The NPA Business Plan for 2006/07 links its key objectives to the Race Equality Scheme to ensure that race equality issues are mainstreamed in the business process. The Chief Officer of NPA is currently the Chair of the Norfolk Criminal Justice Board Race Action Group which works to deliver a race action plan. One of the key achievements in 2004 was a community information event for Black and minority ethnic community groups, hosted by the Norfolk CJB in partnership with a number of voluntary partner organisations, as part of its community engagement strategy. The event received very positive feedback from participants and enabled the Norfolk CJB to develop its own BME community data base. The Race Action Group also seeks to develop more collaborative ways of working among all the criminal justice agencies in promoting race equality. The Diversity Manager attends the County Managers’ meeting chaired by the Chief Officer on strategic and operational issues of the service. This creates a forum for raising diversity issues and thus mainstreaming them into the business. The Diversity Manager also attends team meetings in the field teams to hold two-way dialogue with staff on diversity issues. There is a staff team of volunteers (10 members of staff) known as Diversity Champions who are coordinated by the Diversity Manager. The role of the Diversity Champions is to provide information, advice and support to their local field teams on diversity issues and to help organise diversity events and other projects. For example, in 2005, the Group organised events for Diversity Week. Board members are involved in community engagement through events such as the Diversity Garden celebration in September 2005 and the Local Crime, Community Sentencing (LCCS) project which has visited about 10 community organisations in 2005. 11

4. Leadership - Action points and expected outcomes • Ensure there is effective communication between senior management team and staff on diversity issues through feedback from staff focus groups and staff surveys. • Publicise leadership involvement in community events both internally and externally – eg. the LCCS project. • Ensure appropriate support for Diversity Champions and other staff support networks whose leadership work is key in monitoring and improving staff commitment to diversity.

5. Consultation and Community Engagement • NPA aims to maintain clear standards for assessment, monitoring and presentation and recognises the importance of public access to information and services in achieving public confidence in the criminal justice system. • NPA is a member of a local partnership alongside a number of key statutory agencies who have signed up to a Partnership Agreement with INTRAN to provide an interpreting and translation service to our service users. This locally provided service enables an efficient service to meet the language and communication needs of our service users. • NPA’s equality monitoring data is disseminated at different levels: local, regional and national to inform policy development. • The results of the impact assessments on existing and new policies are published on the intranet which is available to staff and are available to the public as part of the Open Meetings process. • Feedback to BME communities is carried out on an informal basis, through the community development undertaken by the Diversity Manager and other staff involved in partnership work. • NPA also makes use of any nationally published materials such as the Complaints leaflet and summary of the Race Relations (Amendment) Act and distributes these to local communities. • Policy developers are guided by the NPA Policy Development Framework to consult and engage with stakeholders to ensure that any policy implementation will not have a detrimental effect on any specific groups. • NPA proactively seeks out opportunities to engage with BME communities by participating in local events such as Black History Month. Local BME and faith groups are also invited to NPA events such as the launch of the Unpaid Work scheme in 2006.

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6. Consultation and Community Engagement - Action points and expected outcomes • Establish a structured consultation mechanism with Black and minority ethnic communities in undertaking equality impact assessment of NPA’s functions and policies and work collaboratively with other criminal justice agencies on large-scale consultations with BME communities and organisations where there are common themes. • Establish a system of communication with BME communities and organisations to publish/communicate results of consultations and the Race Equality Scheme. • Ensure public access to information and services by implementing the community engagement programme and NPA' external communications strategy. In addition, we will make use of our link with the NNREC through the Service Level Agreement in delivering this objective.

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7. Communication and Information • NPA makes use of publications by the NPS which give information about our services, particularly the information relating to careers in the NPS. • Details of our services are also published in the Race Equality Scheme in the list of functions and policies which have been the subject of equality impact assessment since 2003 and are relevant to the General Statutory Duty. • NPA has also made this information available at community engagement events. The Norfolk Criminal Justice Board hosted a Black and minority ethnic community event in February 2005 where information about the work of all the criminal justice agencies was provided. More importantly, the experiences of Black and minority ethnic people within the criminal justice system were shared and noted at this event. Issues are being addressed through the CJB Race Action Plan. • Through our work with Black and minority ethnic offenders, we are also disseminating their service experiences in order to eliminate any discriminatory practice and treatment. For example, through a complaint from an offender of minority ethnic background, we became much more aware of the importance of addressing their specific service needs. • The process by which we identify any barriers to equitable access to information and services is via our equality impact assessment process at policy formulation stage (as described above). The equality impact assessment process also addresses accessibility issues. • NPA ensures that its Accessibility Guidelines are updated to address the needs of all service users and that all staff receive training on its operation. • Through our partnership agreement with INTRAN which provides a language and communication service, we are also able to disseminate feedback from service users to inform our service provision. • The Diversity Manager has a community engagement/development remit and has made good contacts with Black and minority ethnic communities and organisations since her appointment in August 2004. • The Board has appointed a Communications Officer who started in post in February 2006. The role of the Communications Officer will fulfil NPA’s strategic direction of improving communication with our staff, external partners, other criminal justice agencies as well as the community of Norfolk.

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8. Communication and Information – Action points and expected outcomes • Monitor the effectiveness of INTRAN and ensure all staff have information about accessing INTRAN. • Publicise the availability of INTRAN so that service users are aware of such support to help them access probation services. • Maintain a current list of the most commonly used community languages and consider the production of NPA publicity leaflets and other materials in the most commonly used languages. • Produce an annual leaflet for our external partners and community groups and voluntary organisations to give a summary of our Race Equality Scheme and highlight our achievements and our progress on Race and Diversity Impact Assessment. This leaflet will also invite comments and feedback from the community and will be produced in a variety of our community languages.

9. Services for offenders • NPA works closely with the region through the Regional Diversity Management Group on the Reducing Re-offending Action Plan, to ensure that the diversity ‘strand’ is integrated into all the pathways. • Race and ethnic monitoring data on offenders to be returned on time and using the correct (Census 2001) classification* (*In NPA, the form to be used by staff is known as PREM1) • Improve the quality of reports on minority ethnic offenders to achieve parity in quality of provision as for white offenders by comparing outcomes between BME and white offenders for similar offences and criminogenic factors. • Ensure that individuals and organisations from minority ethnic groups are fully represented as beneficiaries of community punishment projects. • NPA needs to review its services to women offenders and develop a strategy to address their needs, or any gaps in provision as established by such a review. • Formulate a policy on Domestic Violence and ensure that interventions (accredited programmes) and other support meet the needs of Black and minority ethnic communities. • NPA will ensure that its Complaints Procedure is publicised and is easy to access for offenders.

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10. Services for offenders - Action points and expected outcomes • Continue to monitor reports and performance against key targets by social identity (gender, race, age, disability, sexual orientation, and faith) to ensure that no particular groups are being discriminated against and suffer a detriment as a result. • Develop a Strategy for Women Offenders which pays particular attention to the needs of Black and minority ethnic women offenders • Establish an Unpaid Work Community Panel to ensure that individuals and organisations from minority ethnic groups are fully represented as beneficiaries of community punishment projects. • Work in partnership with Norfolk Criminal Justice Agencies to ensure that hate crime is reported using the third party reporting system ‘True Vision’.

11. Services for Victims • Race and ethnic monitoring data on victims to be returned on time and using the correct (Census 2001) classification*. (*In NPA, the form to be used by staff is known as PREM1) • Ensure the services of Victim Liaison Officers are publicised among Black and minority ethnic communities and voluntary agencies. • Ensure that the new policy on Domestic Violence takes account of the experiences and issues arising from Black and minority ethnic communities and that support services for victims are appropriate and accessible to these communities and agencies. • Work in partnership with Norfolk Criminal Justice Agencies to ensure that hate crime is reported using the third party reporting system ‘True Vision’.

12. Services for victims - Action points and expected outcomes • Monitor the percentage of return for race and ethnic monitoring data and identify gaps in service provision. • Produce publicity leaflets about the work of Victim Liaison Officers and promote at community events. • Consult with Black and minority ethnic communities in developing the policy on Domestic Violence to ensure that it takes account of the experiences and issues faced by BME communities. • Promote ‘True Vision’ reporting system among staff and community groups and organisations.

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13. Employment NPA meets its employment duties by using the following established mechanisms: • An employment monitoring system which monitors the equality areas of gender, ethnicity, faith, disability, sexual orientation and age, and maintains a profile of the number of staff in post and their grades. • Monitoring of the entire recruitment process: from application, shortlisting, assessment centre to final appointment stage. • A recruitment and selection process which is based on clearly identified competencies or criteria. • Members on interview panels undertake a two-day recruitment and selection training which focuses on fair recruitment process and practice. • Diversity issues are integrated in the job description and person specification and candidates are assessed on their understanding of and competence in diversity issues. • NPA scrutinises the exit data of staff and analyses any pattern or underlying issues relating to equality and diversity. • NPA monitors the grievance procedures and disciplinary actions and the outcomes of these actions. • An annual report on the outcomes of the recruitment procedures is presented to the Board and any pattern of under/over-representation is examined to inform our recruitment, selection and retention strategy. • NPA Equality Working Group scrutinises all of the above monitoring data on a regular basis and locates any adverse impact on specific groups of staff and devises strategies to remove identified barriers. • NPA has launched its Harassment Policy and, as part of its support for staff, there is a Harassment Support Scheme. The scheme is staffed by volunteers from all grades and field teams who have received training to provide support for staff who believe they have been the subject of bullying and harassment in the workplace. This scheme is coordinated and managed by the Diversity Manager. Data will be collected by social identity to monitor any pattern of harassment or discrimination for minority groups. • NPA aims to maintain an effective communication system with staff, for example, through regular staff brief, staff focus groups and staff surveys.

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14. Employment - Action points and expected outcomes • Devise recruitment procedures that reach socially, ethnically and geographically diverse prospective employees to continue to develop a skilled and diverse workforce. • Monitor the harassment support scheme to identify any pattern of harassment or bullying based on specific social identity groups to ensure a safe, harmonious and healthy working environment. • Use a variety of media such as Staff Brief, the Diversity Champions, Staff Focus Groups and other events to maintain effective communication and to provide a forum for diversity issues to be voiced. • Support minority staff support networks organised locally or through the Regional Diversity Management Group by encouraging the attendance of minority groups of staff at network meetings and other events. • Participate in the NPD positive action programme such as ‘Accelerate’ to promote greater diversity at senior management level.

15. Training • The Diversity Manager has a training remit and has produced a Diversity Training Strategy and a Training Plan. The arrangements for staff and Board Members to receive diversity training which incorporates the Duty under the RRAA began in 2003 and are continuing. All staff and Board Members are required to undertake a diversity training programme. For new staff, the training day is incorporated into the week-long Staff Induction Programme in their first week of commencing employment in NPA. • In addition to the above training programme (mandatory), the training needs of staff are identified through the annual performance management process. • The diversity training programmes have been designed to provide role-specific training to ensure that it is relevant to the specific duties. • All training activities are subject to a participant evaluation process which includes evaluation of equality practice. • A new database for monitoring the learning and development activities of all staff has been implemented. This provides clear information on attendance and the individual portfolio of Learning & Development. • NPA has recruited a group of staff volunteers who fulfil the role of Diversity Champions. The Diversity Champions have received diversity training and are engaged in diversity projects and other activities which promote equality and diversity across the area. This group will continue to develop their skills and knowledge on diversity issues.

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16. Training - Action points and expected outcomes • Ensure that the Diversity Training Strategy and Training Plan are incorporated into NPA’s overall Training Strategy and that resources are available for its successful delivery. • Scrutinise the output of evaluation mechanisms for training activities and ensure that diversity practice is promoted and that any issues are addressed. • Scrutinise the monitoring of learning and development activities of all staff to ensure that NPA is practising equality of opportunity for all staff groups.

17. Setting Priorities The NPA Business Plan sets out priorities at national level and identifies key objectives to be achieved. These objectives are translated into performance targets and responsibility for delivery is clearly identified. Priority 6 in Business Plan 2006/07 covers Equality and Diversity. It states NPA’s commitment to implementing its Race Equality Scheme and its Diversity Strategy as well as the process for equality impact assessment.

18. Action points and expected outcomes The performance targets in relation to Priority 6 for 2006/07 include the following: • To meet regionally set employment targets for minority ethnic staff – 4.9% • Race and ethnic monitoring data on staff to be returned on time and using the correct (Census 2001) classification – 95% • Race and ethnic monitoring data on offenders to be returned on time and using the correct (Census 2001) classification – 95%

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19. Local Issues Local issues are identified in a number of ways: • Community development work with local Black and minority ethnic community groups and voluntary organisations • The local criminal justice board – Norfolk Criminal Justice Board Race Action Group which has a Race Action Plan • The 6 Co-opted members from local Black and minority ethnic community and organisations • Local partnership such as the Norfolk Crime and Disorder Reduction Partnership • The Regional Reducing Reoffending Action Plan • EFQM self-assessment process completed in September 2005 • Staff Survey – to be undertaken in June 2006 • Staff focus groups – undertaken in February and September 2005 with more to be scheduled in 2006 • Complaints procedure – monitoring of complaints and analysis of issues (annual report produced by Chief Officer) • Local reviews and surveys – the Race Equality Scheme Review undertaken by the Norfolk and Norwich Race Equality Council in 2004/05 and the Diversity Audit undertaken by the Audit Commission in the East of England in 2005 • Thematic reports – eg. Effective Supervision where there are implications for NPA 20. Local issues - Action points and expected outcomes Race and diversity issues that arise out of the above sources are incorporated into the NPA Business Plan, its Race Equality Scheme and Diversity Action Plan. There is a clear structure for the monitoring and reporting of all the action points and outcomes via the Equality Working Group.

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21. Action Plan and Performance Targets The actions listed below have been formulated into the NPA Diversity Action Plan which will set out clearly the performance targets and expected outcomes.

Actions arising from the Review of the 2002-05 Race Equality Scheme • Assess the functions of NPA relevant to the General Duty in promoting race equality by identifying specific race and diversity issues in the unit plans. • Establish a structured consultation mechanism with Black and minority ethnic communities in undertaking equality impact assessment of NPA’s functions and policies, and work collaboratively with other criminal justice agencies on large-scale consultations with BME communities and organisations where there are common themes. • Establish a system of communication with BME communities and organisations to publish/communicate results of consultations and the Race Equality Scheme. • Analyse race and ethnic monitoring data collected in respect of offenders and scrutinise for any pattern of discrimination or barriers to services. • Establish a structured approach to consulting with offenders and victims and ensure feedback is given to them on how their views have influenced policies and practice. • Ensure that partnership agencies involved in the delivery of services on our behalf are consistent in undertaking race and ethnic monitoring and adopt the Census 2001 16+1 categories. • Ensure public access to information and services by implementing the community engagement programme and NPA’s external communications strategy. In addition, we will make use of our link with the NNREC through the Service Level Agreement in delivering this objective. • Integrate diversity training into the mainstream training programme. • Develop a diversity competency framework and link this to assessments, performance management and training and development. • Analyse data on staff promotions and present regular reports to the Equality Working Group.

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Race Impact Assessment - Action points and expected outcomes • Monitor the whole process of Race and Diversity Impact Assessment to ensure that there are tangible and positive outcomes in compliance with the General Duty. • Monitor the effectiveness of the co-opted members and ensure they are fully integrated into the work of the Board and contributing to NPA’s community engagement agenda. • Maintain a list of the policies and functions for the purpose of Race and Diversity Impact Assessment to ensure that all policies and functions relevant to the General Duty are subject to the impact assessment process. (Annex 1 and Annex 2)

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Leadership - Action points and expected outcomes • Ensure there is effective communication between senior management team and staff on diversity issues through feedback from staff focus groups and staff surveys. • Publicise leadership involvement in community events both internally and externally – eg. the LCCS project. • Ensure appropriate support for Diversity Champions and other staff support networks whose leadership work is key in monitoring and improving staff commitment to diversity.

Consultation and Community Engagement - Action points and expected outcomes • Establish a structured consultation mechanism with Black and minority ethnic communities in undertaking equality impact assessment of NPA’s functions and policies and work collaboratively with other criminal justice agencies on large-scale consultations with BME communities and organisations where there are common themes. • Establish a system of communication with BME communities and organisations to publish/communicate results of consultations and the Race Equality Scheme. • Ensure public access to information and services by implementing the community engagement programme and NPA' external communications strategy. In addition, we will make use of our link with the NNREC through the Service Level Agreement in delivering this objective.

Communication and Information - Action points and expected outcomes • Monitor the effectiveness of INTRAN and ensure all staff have information about accessing INTRAN. • Publicise the availability of INTRAN so that service users are aware of such support to help them access probation services. • Maintain a current list of the most commonly used community languages and consider the production of NPA publicity leaflets and other materials in the most commonly used languages. • Produce an annual leaflet for our external partners and community groups and voluntary organisations to give a summary of our Race Equality Scheme and highlight our achievements and our progress on Race and Diversity Impact Assessment. This leaflet will also invite comments and feedback from the community and will be produced in a variety of our community languages.

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Services for offenders - Action points and expected outcomes • Continue to monitor reports and performance against key targets by social identity (gender, race, age, disability, sexual orientation, and faith) to ensure that no particular groups are being discriminated against and suffer a detriment as a result. • Develop a Strategy for Women Offenders which pays particular attention to the needs of Black and minority ethnic women offenders • Establish an Unpaid Work Community Panel to ensure that individuals and organisations from minority ethnic groups are fully represented as beneficiaries of community punishment projects. • Work in partnership with Norfolk Criminal Justice Agencies to ensure that hate crime is reported using the third party reporting system ‘True Vision’.

Services for victims - Action points and expected outcomes • Monitor the percentage of return for race and ethnic monitoring data and identify gaps in service provision. • Produce publicity leaflets about the work of Victim Liaison Officers and promote at community events. • Consult with Black and minority ethnic communities in developing the policy on Domestic Violence to ensure that it takes account of the experiences and issues faced by BME communities. • Promote ‘True Vision’ reporting system among staff and community groups and organisations.

Employment - Action points and expected outcomes • Devise recruitment procedures that reach socially, ethnically and geographically diverse prospective employees to continue to develop a skilled and diverse workforce. • Monitor the harassment support scheme to identify any pattern of harassment or bullying based on specific social identity groups to ensure a safe, harmonious and healthy working environment. • Use a variety of media such as Staff Brief, the Diversity Champions, Staff Focus Groups and other events to maintain effective communication and to provide a forum for diversity issues to be voiced. • Support minority staff support networks organised locally or through the Regional Diversity Management Group by encouraging the attendance of minority groups of staff at network meetings and other events. • Participate in the NPD positive action programme such as ‘Accelerate’ to promote greater diversity at senior management level.

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Training - Action points and expected outcomes • Ensure that the Diversity Training Strategy and Training Plan are incorporated into NPA’s overall Training Strategy and that resources are available for its successful delivery. • Scrutinise the output of evaluation mechanisms for training activities and ensure that diversity practice is promoted and that any issues are addressed. • Scrutinise the monitoring of learning and development activities of all staff to ensure that NPA is practising equality of opportunity for all staff groups.

NPA Business Plan Priorities and expected outcomes The performance targets in relation to Priority 6 for 2006/07 include the following: • To meet regionally set employment targets for minority ethnic staff – 4.9% • Race and ethnic monitoring data on staff to be returned on time and using the correct (Census 2001) classification – 95% • Race and ethnic monitoring data on offenders to be returned on time and using the correct (Census 2001) classification – 95%

List of supporting information available on request 1. NPA Policy Development Framework Document and NPA Diversity Impact Assessment template and guidance 2. NPA Diversity Policy 3. NPA Diversity Action Plan 4. NPA Diversity Training Strategy and Training Plan 5. List of NPA policies impact assessed in the last Race Equality Scheme 6. Role of Diversity Champions 7. NPA Business Plan 8. NCJB Race Action Group – Race Action Plan 9. NPA Accessibility Guidelines 10. List of functions and policies relevant to the General Duty

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ANNEX 1 Norfolk Probation Area Race Equality Scheme – Policies and Functions which have been impact assessed since 2002: Car Lease Scheme Harassment Animals on Probation Premises Performance Management Scheme Financial Handbook Grievance Procedure Induction Policy Funding of Staff for Personal Development Strategy for Accredited Programmes Joint Agreement on Priorities and Employee Care Risk Management Policy Health and Safety Policy Diversity Policy Managing the Work/Life Balance – Requesting flexible Working Reporting Concerns at Work (Whistleblowing) Employing People with Disabilities Sickness Management Procedure Interpreting and Translation Policy Internal Communications Policy Offender Employment Policy and Strategy Business Process Improvements Data Protection Guidance Accredited Programmes Code of Conduct for Staff Section E – Financial Procedures Guidance on Leave Financial Handbook – travel and subsistence Employer Engagement Policy Anti-Fraud Strategy Race and Ethnic Monitoring Process Prolific and Other Offender Policy John Boag House Drug Misuse Policy John Boag House Policy and Strategy on Valuing Diversity Regional HR Policies: • Special Leave • Flexible Working • Staff Recognition Scheme • Adoption Leave • Benefits for Staff Involved in the Care of Children Offender Accommodation Policy & Strategy External Partnership Policy & Strategy Drug Testing Prolific and Other Priority Offenders – Policy & Guidance Policy on funding Staff Development Opportunities Stress Management Investigation of accidents and incidents New and expectant mothers Home working Complaints Procedure 26

Offender Management Policy Risk Management Policy Serious Further Offences Committed by Supervised Offenders Working with Life Sentence Prisoners External Communications Policy Guidance on Leave Flextime system Managing work-life balance Employing people with disabilities Norfolk Offender Management Model Crime and Disorder Reduction Policy Unpaid Work Visibility and Community Engagement Policy and Strategy 2005-2007 NPA Mentor Policy Racially Motivated Offenders Policy

(Updated 2006)

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ANNEX 2 Norfolk Probation Area Race Equality Scheme 2005 – 2008 List of Policies to be assessed as agreed by the Equality Working Group for 2007/08 Policy on working with sex offenders Policy on working with Schedule 1 offenders Staff Reduction Policy Sickness Management Policy Discipline and capability procedure Interpreting and Translation Policy Domestic Abuse Policy Safeguarding Children Straegy and Policy Procurement and contract management Strategy and Policy Staff Reitrement Policy Women Offenders’ Policy and Strategy Access to Personal Files Staff Appraisal Scheme Disability Equality Scheme Gender Equality Scheme DIP Strategy and Policy

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Norfolk Probation Area
Gender Equality Scheme 2007-2010

Contents 1 2 2.1 2.2 2.3 3 3.1 3.2 3.3 3.4 4 5 6 7 Introduction by Martin Graham, Chief Officer General introduction of the Gender Equality Scheme Norfolk Probation Area Aims and Objectives Values and Commitment to Diversity Duties under the Gender Equality Act 2006 General Duties Specific Duties Duties for Transsexual People Duty to Eliminate Harassment Key Priorities and Outcomes of the Scheme Gender Equality and Service Delivery Gender Equality and Employment Gender Equality Action Plan 2007-2010

Annex A Annex B

NPA Policy Development Framework Equality Impact Assessment template

If you require this document in another format please contact: Rowena Kerr, Diversity Manager Tel: (01603) 220107 Email: rowena.kerr@norfolk.probation.gsi.gov.uk

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Introduction by Martin Graham, Chief Officer

I am very pleased to introduce Norfolk Probation Area’s Gender Equality Scheme which has been developed as part of our Equality Duty under the Equality Act 2006. This means that as a public service employer and provider, we have a duty to eliminate unlawful discrimination and harassment and promote equality of opportunity between women and men.

The integration of equality and diversity values are paramount in everything we do. Our Diversity Policy states clearly our vision and aims and our Business Plan translates these stated aims into measurable actions and outcomes. Gender equality is one of the diversity areas that has long been enshrined in our diversity policy, our employment policies as well as in the assessment, intervention and monitoring arrangements for offender management. The introduction of the new Gender Equality Duty therefore presents a timely opportunity for us to continue to develop in this area as there remain many challenges in achieving genuine equality of outcome. For example, the issue of women offenders is high on the national agenda and we are committed, as stated in our Business Plan for this year, to implement a policy for women offenders to address some of the key and pressing issues.

Our Gender Equality Scheme sets out our commitments and the actions we will take under the strategic areas of leadership commitment, workforce diversity and equality, equal and accessible services, community engagement and communication and legislative duties. We recognise that leadership commitment is vital in enabling and sustaining changes and as such the Equality Working Group and our co-opted community members as well as the Diversity Champions will have a key role to play in influencing attitudes, scrutinising practices and driving for change.

Martin Graham Chief Officer

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2 2.1

General Introduction of the Gender Equality Scheme Norfolk Probation Area Norfolk Probation Area (NPA) is one of 42 local areas which make up the National Probation Service (NPS) within the National Offender Management Service (NOMS). The aims of the NPS are: Protecting the public Reducing re-offending Ensuring the proper punishment of offenders in the community Ensuring offenders’ awareness of the effects of crime on the victims of crime and the public Rehabilitation of offenders The establishment of NOMS provides a new context for work with offenders which provides: A focus on offender management with a single offender manager responsible for assessing need, selecting and sequencing interventions; The use of commissioning to separate the identification of need from the delivery of services; A regime of contestability to challenge existing providers to demonstrate they can continue to provide the best value in terms of both cost and quality whilst meeting the diverse needs of service users. The NPA Business Plan “Positive Outcomes for People” for 2007/08 sets out the following key deliverables: Offender Management which holds offenders to account but recognises the value of each individual and their capacity to change; Interventions which meet the identified criminogenic needs of offenders delivered both in-house and in partnership with a range of voluntary and private organisations; Protection for the public of Norfolk by close inter-agency working with other organisations within the Criminal Justice System; Re-assurance for victims of crime through the reduction of reoffending and the effective management of offenders; Development and training opportunities for staff which enable them to be properly skilled to carry out their different roles within NPA; A safe and healthy working environment which promotes the development of individuals’ potential;

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A culture of helping individual staff to achieve their potential. 2.2 Aims and Objectives

NPA’s Gender Equality Scheme (GES) sets out our commitment and arrangements on how we will fulfil our Gender Equality Duty, promote equality of opportunity for women, men, and to challenge harassment and discrimination against them. The Scheme applies to women and men working for NPA and those using our services. The Scheme also covers transsexual people, who have either undergone, are currently undergoing or intending to have gender reassignment. 2.3 Values and Commitment to Diversity

The NPA’s values and commitment to diversity are stated in our Diversity Policy as follows: Norfolk Probation Board commits itself to equal service for all staff, offenders, victims of crime and our communities regardless of social identity. Equal service means fair, accessible, inclusive, appropriate and effective provisions in employment and service delivery practices. Social identity includes age, class, disability, ethnicity, faith, gender and sexual orientation. We acknowledge that individuals have diverse social identities and therefore in promoting our new Gender Equality Duty we are delivering it in unison with our duties under the current equality legislation for race, age, belief, disability and sexual orientation through a strategic approach. Norfolk Probation Board also recognises its leadership role in promoting diversity and equality of opportunities in all the relevant strands. It is therefore committed to implementing organisational structures, policies and services that fulfil not only our legal duties but also redress inequalities and yield positive changes. The concept of leadership will emanate from board level through diverse representation including the recruitment of co-opted members from the community through to the structure of Diversity Champions across NPA. Our strategic focus for diversity therefore covers the key areas of: Leadership Commitment Workforce diversity and Equality Equal and Accessible services Community engagement and communication, and Legislative duties

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3 Duties under the Gender Equality Act 2006 3.1 General Duties

NPA Board is aware of its commitment to take a proactive approach to meeting their general duties under the Gender Equality Act 2006 to: Eliminate unlawful discrimination Eliminate harassment Promote equality of opportunity between men and women The Board is aware that although the three parts of the duty may support each other and overlap, it understands that each duty is different and that achieving one may not lead to achieving all three areas. 3.2 Specific Duties

Specific duties under the Gender Equality Act include the following: Prepare and publish a Gender Equality Scheme Include objectives to address the causes of any gender pay gap Gather and use information on how NPA’s policies affect gender equality in the workplace and in the delivery of services Consult stakeholders (employees, service users and partners) to determine its gender equality objectives Assess the impact of current and proposed policies and practices on gender equality Implement the actions set out in this scheme Report on progress of the scheme and conduct a review The following sections set out our current arrangements while identifying areas for action: (i) NPA Gender Equality Scheme The NPA Board is pleased to produce its first Gender Equality Scheme (GES), showing how it intends to fulfil its general and specific duties, including an action plan setting out its gender equality objectives and outcome measures over the life of the scheme (2007-2010). The GES is a living document and the NPA Board welcomes comments and suggestions from its employees, service users, partners and other stakeholders. The Scheme and Action Plan will be subject to an annual review and further information will be published to all stakeholders via a range of media. Under our Accessibility Guidelines,

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our GES can be made available in a variety of formats such as large print or Braille, or in another language. (ii) Objectives to address the causes of any gender pay gap To ascertain whether there is a gender pay gap within NPA’s workforce, an audit on samples of jobs within each pay band have been examined. NPA’s salaries fall within 6 pay bands plus Chief Officer Grades. The pay band for each job has been determined by a comprehensive job evaluation process, conducted in 2006. The audit which was carried out following the job evaluation does not show any evidence of a gender pay gap in Norfolk Probation Area. However, NPA will continue to monitor any pattern of apparent pay gap as part of its gender equality duty. Gathering and using information on how NPA’s policies affect gender equality in the workforce and in the delivery of services Employment Monitoring Data: The Human Resource Department maintains a staff monitoring database by age, disability, ethnicity and gender. Information is collected at pre-employment stage and updated throughout the period of employment of all NPA staff. The Human Resource Manager produces a report bi-annually to the Workforce Working Group of staff diversity profiles relating to the following areas: Grade Job application and appointment Career Progression Grievance procedures Disciplinary procedures Harassment cases Performance appraisal procedures Dismissals and other reasons for leaving The purpose of the employment monitoring is to detect any pattern of discrimination by age, disability, ethnicity or gender. Where there are issues arising, strategies will be devised to eliminate such discriminatory practices. In addition to quantitative data collected via the above mechanisms, NPA also conducts staff surveys and focus groups where ‘softer’ data is obtained. This will provide insight into the cultural issues about the organisation and will be disseminated via the management structure of SMT and the Board. Equality monitoring of service users: NPA collects equality data relating to age, disability, ethnicity, gender of service users. The data is entered on case files via existing data systems which are subject to quality audits and diversity monitoring. In particular, the following aspects are scrutinised in quality audits:

(iii)

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Risk of harm Rescores of OASys to assess changes in risk levels at the end of supervision Tracking reports to demonstrate consistency (undertaken by Offender Managers) Results of psychometric testing for offenders undertaking programme Post programme reports The following performance areas are also subject to diversity monitoring including gender monitoring: Breaches Compliance Concordance Programme completions Unpaid Work completions Victim contact Accommodation Skills for life Retained on DTTO/DRR for 12 weeks Performance reports will be scrutinised for any emerging pattern of gender discrimination and appropriate strategies will be devised to address identified areas of inequalities. (iv) Consultation with stakeholders (employees, service users and partnership agencies) to determine our equality objectives The equality objectives in our Action Plan have been formulated from national and local priorities as well as the outcomes of the following consultations held in 2006: Staff survey During 2006, NPA conducted a staff survey. A total of 121 staff responded out of a total of 338, representing a response rate of 36%. The gender breakdown of the response rate was proportionate to the gender profiles of the workforce: 31% of respondents were male who comprise 35% of the workforce; 69% of respondents were female who comprise 65% of the workforce in NPA. The survey also contained a specific section on equalities which focussed on harassment and bullying. Over two thirds of employees (70%) in the survey reported that they had not experienced or witnessed any type of harassment, bullying or discrimination. Of the one third (28%) who indicated they had experienced or witnessed harassment or discrimination, half of them had reported it to someone in the organisation. However, half of those who had reported the incident felt that it had not been dealt with

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satisfactorily. About a quarter of the respondents felt that NPA should take action to improve equal opportunities. A copy of the action plan to address issues arising from the Staff Survey 2006 is available on request. Offender Satisfaction Survey In 2006, NPA conducted a satisfaction survey with offenders on their perception and experience of a range of service provisions. Given the low representation of female service users in the survey (29 compared to 264 male offenders), it was not viable to make any meaningful interpretation from the data. A key learning from the survey is to conduct focus groups with women offenders where their perception and experience of our service can be explored in greater depth. However, the experience and equality outcomes for women within the criminal justice system have been well documented nationally (e.g. The National Probation Service’s Good Practice Guide on “Delivering Effective Services for Women Offenders in the Community” (November 2006) and the Corston Report (Home Office 2007). NPA has developed a policy for women offenders which seeks to provide effective services to meet the rehabilitative needs of women offenders to prevent re-offending and effective interventions to reduce risk of harm to the public. (See Section 5 Gender Equality and Service Delivery). Partnership Agencies In September 2006, NPA held a diversity workshop with our partnership agencies where issues and good practice on diversity were shared and discussed. Partnership agencies welcomed the forum to share good practice and raise service issues. NPA will continue to develop this way of working with partnership agencies and other stakeholders so that equality and diversity issues can be addressed systematically and collaboratively across all of our contracted service providers. (v) Impact assessment of current and proposed policies and practices on gender equality The key purpose of the equality impact assessment process is to examine any adverse impact on specific social identities in order to eliminate any inequality of outcomes. All of NPA’s policies and procedures are subject to impact assessment. Our arrangements are: All policy development and review are subject to the NPA’s Equality Impact Assessment (EIA) process, using the Framework for Developing Policy, Strategy, Processes and Guidelines (Annex A) and the Equality Impact Assessment template (Annex B). All policies are presented to the Equality Impact Assessment Group which comprises officers and co-opted members representing a

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diverse range of equality and diversity issues from the community. Following the EIA process, the policies are presented to the main Equality Working Group for final scrutiny and then presented to the Board for final approval. The Equality Working Group maintains a prioritised list of functions and policies and a timetable for the regular review of these functions and policies. The prioritisation of functions and policies is guided by national priorities and are assessed in terms of their relevance to the Gender Equality Duty. NPA is committed to undertake the statutory 3-year gender equality review of our functions and policies and new policies. All NPA policy documents show date of origination of policy and review dates as well as the name of the policy developer. All policies which have been impact assessed are recorded in the minutes of the Equality Working Group and available on the intranet. All policies are also subject to ongoing monitoring via regular reports to the relevant working groups. For example, employment reports which include information (broken down by age, disability, gender and ethnicity) on recruitment, sickness absences, grievance/disciplinary cases are presented to the Workforce Working Group and the Equality Working Group on a regular basis. Our EIA process covers the equality areas of age, disability, ethnicity, gender, faith, sexual orientation and class and has been in operation since the implementation of the Race Relations Amendment Act in 2003. (vi) Implement Actions set out in this Scheme Section 7 contains NPA’s Action Plan for implementing its Gender Equality Scheme. The actions are set out under the five strategic areas for diversity: Leadership Workforce Diversity and Equality Equal and Accessible Services Community Engagement and Communication Legislative Duties All the actions are set out using SMART objectives and prioritised according to national and local priorities. The implementation and monitoring of the action plan will be via:

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Monthly review by ACO (Support Services) and Diversity Manager during monthly supervision meetings NPA’s Equality Working Group which meets bi-monthly Half yearly reports of Diversity Action Plan to the Equality Working Group and the Board. Annual review of the Gender Equality Scheme and report to Equality Working Group and the Board. 3.3 Duties for Transsexual People NPA recognises its duty to have due regard to the need to eliminate unlawful discrimination and harassment against transsexual people. The terms transsexual is used to describe a person who intends to undergo, is undergoing or has undergone gender reassignment. NPA’s diversity policy covers individuals (staff and offenders) who are transsexual and are usually considered within the context of Lesbian, Gay, Bisexual and Transgender (LGBT). NPA makes use of the national support network LAGIP (Lesbians, Gay Men, Bisexual and Transgendered Individuals in Probation) which includes transsexual issues. NPA also took part in a regional event in February 2007 to celebrate Gay History Month and featured a speaker from LAGIP. NPA recognises that transsexual issues both in terms of employment and service delivery need to be raised to a higher profile so that there is better understanding of the needs of individuals and that our support and services are appropriate to their needs. In particular, NPA will examine provision for transsexual people in its Approved Premises. 3.4 The Duty to Eliminate Harassment NPA recognises the need to eliminate harassment, including sexual harassment, as a general duty. NPA has a policy which aims to eliminate and prevent harassment and bullying in the workplace. The aim of the NPA Harassment Policy is to:promote awareness amongst staff of the different forms that harassment and bullying may take inform staff at all levels of the organisation of their responsibilities to ensure that the working environment is free from oppressive behaviour promote awareness of the procedures that we have to help members of staff if they feel that they are being harassed or bullied The coverage of the NPA Harassment Policy includes the following specific areas:

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Sexual harassment Racial harassment Harassment of people with disabilities or learning difficulties Harassment of lesbians, gay men and bisexuals Harassment of transgendered and transsexual individuals Harassment of individuals on religious grounds Harassment Support Scheme As part of the support system within the Policy, NPA operates a Harassment Support Network which provides for 12 members of staff who are trained volunteers to act as support workers to anyone who may have experienced harassment or who have been implicated in a harassment case. The scheme is managed by the Diversity Manager who holds regular meetings with the Support Workers to examine the monitoring data (aggregated and anonymously) to detect any pattern in terms of types of incidents and social identity indicators. For example, any gender issues in harassment cases could be highlighted.

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4 4.1

Key Priorities and Outcomes of this Scheme NPA has developed an Action Plan as part of its Gender Equality Scheme. Our key priorities in the first year of the scheme relate to the following areas: Implementation of the Domestic Violence Policy Implementation of the Women Offenders Policy Implementation of the True Vision third party reporting for Hate Crime Implementation of the Procurement Policy that integrates diversity into its tender and contract arrangements Implementation of the actions arising from the Staff Survey 2006 (in particular those relating to harassment)

4.2

Diversity monitoring statistics suggest that men are under-represented at some levels of the organisation and over-represented at others. NPA will seek to discern the reasons for this and if appropriate will develop remedial strategies. In implementing the NPA Gender Equality Scheme, we expect that the following outcomes will be delivered. These are summarised under the five strategic areas for diversity: Leadership: Clear commitment at leadership level to gender equality which is demonstrated through the vision and values of NPA as well as through organisational structure and resources – for example, Diversity Champions, Harassment Support Network, and Women Safety Workers. Managers and team leaders to demonstrate diversity competency in team management and offender management, assessed via the performance appraisal system The Equality Working Group to have representation on gender and LGBT issues, particularly at co-opted member level Workforce Diversity and Equality: Access to support networks for transsexual staff Harassment Support Workers to receive training in supporting all minority staff groups Review of recruitment procedures to eliminate any gender bias Equal and Accessible Services: Accessible services which take account of the different criminogenic needs of male and female offenders NPA’s performance areas will be scrutinised by gender issues

4.3

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A timetable for the assessment of functions and policies will be published for the first year of the Scheme A procurement policy will be drawn up that addresses gender equality issues to ensure compliance in contract specification and delivery on the part of providers, with reference to our Women Offenders’ Policy Implementation of NPA Domestic Violence Policy Implementation of NPA Women Offenders’ Policy Review of provisions for women on accredited programmes to be undertaken and outcome actions prioritised Community Engagement and Communication: A strategy for engagement and communication with local organisations to be developed NPA community engagement programmes to include organisations and voluntary groups providing services for women offenders Legislative Duties: All staff and managers to have received training or briefing on the Gender Equality Duty All Board Members including co-opted members to have received training or briefing on the Gender Equality Duty NPA procedures for equality impact assessment will include gender equality and comply with the Equality Act 2006 New Gender Equality Scheme published

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5

Gender and Service Delivery – Equal outcomes, different approaches Male and Female Offenders

5.1

Male and female offenders comprise 85% and 15% respectively of the total number of offenders managed by NPA. Women offenders are therefore a small minority within the criminal justice system. However, NPA recognises that there are key differences in the criminogenic factors for men and women offenders and therefore require different approaches in the services we provide for them. The recently published Corston Report calls for the need for a “distinct approach” to address the needs of women offenders: “The new gender equality duty means that men and women should be treated with equivalent respect, according to need. Equality must embrace not just fairness but also inclusivity. This will result in some different services and policies for men and women. There are fundamental differences between male and female offenders and those at risk of offending that indicate a different and distinct approach is needed for women.” (Baroness Corston, 2007) 5.2 Gender differences in Criminogenic Needs

Whilst there is evidence that male and female offenders share many of the same criminogenic needs, their level of importance and dynamic factors differ. Data from the Offender Assessment System 1 (OASys) for Probation Areas in The East of England indicates that 60% of women offenders have relationship needs compared with 37% of male offenders. This data reflects the findings in reports, such as that by the Fawcett Society, who have stated that due to the low number of women’s prisons in the UK, half of women prisoners are in custody more than 50 miles from home. This is particularly damaging for women who are more likely to have a primary care responsibility. Other gender differences in criminogenic needs are shown in emotional wellbeing. 64% of women offenders have emotional wellbeing needs compared to 40% of male offenders. Data available also suggests that women offenders, like men, suffer high levels of drug misuse, but they are also more likely to have mental health problems and to have been victims of domestic violence and sexual abuse. For example, the findings by the Fawcett Society report that 1 in 5 women prisoners have previously spent time in a mental or psychiatric ward and 40% have received help or treatment for mental or emotional problems in the year before coming into prison. Currently, NPA delivers the following functions and provisions for women offenders: Offender Management
1

OASYS is a tool which has been designed for measuring male criminogenic factors and therefore not appropriate for assessing female criminogenic needs. However, no alternative assessment tool is currently available or in use in the UK.

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o Assessment o Sentence Planning o Evaluation Mentoring Interventions: o Unpaid Work requirements o Accredited programmes o Employment programmes Other support services to assist rehabilitation and resettlement include: Accommodation Drug and alcohol treatment Literacy and numeracy skills Approved premises Health and mental health Support for children and families Debt and Finance advice Education and Training Specific support for women who have been abused, raped, or have experienced domestic violence/sexual violence NPA has developed “A Policy and Strategy on Working with Women Offenders” which aims to implement the Government’s strategic aims for women offenders, increase awareness of the differential position of women offenders within NPA and promote positive practice to help ensure that women have equal access to community sentences and appropriate resources to support their sentence plans. The NPA Policy and Strategy on Working with Women Offenders, which will be implemented in the Autumn of 2007, sets out the key actions in the above provisions to address equality of outcomes for women offenders. In addition, NPA will continue to undertake equality impact assessments of its functions and services and to monitor and review the outcomes of its services for women offenders. 5.3 Gender and Victim Services

NPA provides a Victim Contact Unit which offers support and information to those victims who have experienced serious sexual or violent crime. Victims are consulted on intended release plans of previous perpetrators, and informed of important changes which could affect them. Safety concerns are relayed to the Multi-Agency Public Protection Panels which plan for the management of serious offenders. As part of our Integrated Domestic Abuse Programme (IDAP) for perpetrators of domestic violence crime, we operate a Women Safety Support Worker scheme which provides support to victims of domestic violence whose partners are undergoing IDAP.

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One of our key actions in this area is to obtain user feedback to ensure that we are addressing the gender needs of victims appropriately and be better able to make appropriate referrals to other support services and agencies.

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6

Gender and Employment

In establishing any pattern of discrimination on the ground of gender among NPA employees, the following areas of employment have been scrutinised as these are potential areas where inequalities can occur: 6.1 Staff Profile (as at March 2007) Total Number 209 105 Percentage 67% 33%

Women Men

The proportion of female and male staff groups follow a pattern for most probation areas in England and Wales. In our recruitment strategy, we are committed to promoting equality of opportunity for both men and women as an over-representation of any one group can affect the workplace culture. 6.2 Gender by Job Groups (as at March 2007) Women % of total in Group 57% 65.3% 86.9% 80% % of All Females 9% 56% 33% 1.8% Men % of total in Group 42.8% 34.7% 13.1% 20% % of All Males 16% 71% 11.8% 1%

Job Groups

Management Operational/Practitioner Administrative/Specialist Secondments Total

20 124 73 4 221

15 66 11 1 93

In comparison to their proportion in the overall staff profile, the analysis by job groups shows that female staff are about 10% under-presented at Management grade and over-represented at Administrative/specialist grade. Male employees are over-represented by 9% at Management grade and under-represented at the Administrative/specialist grade. A balanced representation is achieved at the Operational/Practitioner level. 6.3 Career Progression

During 2006, 20 employees were promoted comprising 13 females and 7 males. Career progression will continue to be monitored for gender equality. 6.4 (i) Staff Working Patterns (as at March 2007) Part-time working Women 154 53 79% 24% Men 91 14 20.8% 15%

Full-time Part-time % of all part-time posts % of total women/men

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The data shows that more male employees are on part-time contract, compared to their proportion in the overall staff profile than female staff. However, the issue regarding part-time staff is the perception of their treatment in the workplace. For example, some staff commented in the staff survey that they were made to feel less important in the team because they worked part-time hours. An action plan has been drawn up to address all the issues arising from the Staff Survey and a copy of the action plan is available on request. (ii) Flexible working

NPA operates a flexible working policy which has been subject to equality impact assessment. The current arrangements show that that there are 4 females and 4 males who are on flexible working. This shows an overrepresentation of male staff on flexible working as compared to their proportion in the NPA staff profile (March 2007). (iii) Other working patterns

In addition to part-time working and flexible working, NPA offers staff the opportunities to apply for other working patterns to meet their personal circumstances: job-share – where one job is split between 2 individuals on shared arrangements fixed-term contract – where the contract is set up for a fixed period. consolidated hours – where full time hours are worked in 4 longer days instead of 5 days annualised hours – where contractual hours are expressed as the total number of hours to be worked each year. This allows flexible working patterns throughout the year time off in lieu – this allows employees to take time off to compensate for the hours they have worked in addition to their contractual hours. Details of the above working arrangements are set out in our employment policy which has been subject to equality impact assessment. 6.5 Special leave NPA operates a policy governing special leave which make provisions for staff who may need to take leave for a variety of reasons. The provisions take into account diversity issues and will be subject to monitoring as part of the implementation of the GES: Compassionate/bereavement leave Dependants’/carers’ leave Leave for domestic emergencies Religious observance Medical or dental appointments, including fertility treatment and blood/bone marrow donation Study leave

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Leave for child’s first day at school Extended annual leave Jury service or court/tribunal attendance Leave for adjustment to disability Voluntary public service or service in non-regular forces 6.6 Staff involved in the care of children

NPA operates a policy which provides for staff to take leave regarding the following: Maternity or adoption leave Parental or special leave Fertility treatment Antenatal care Childcare In 2006, 10 female employees started maternity leave in 2006. Of the 3 who have returned, 1 is on reduced hours and 1 on flexible hours. 6.7 Applicants and leavers

As part of our equality monitoring, we also monitor the number of applicants and leavers by gender. The data from 2006 shows the following: Applicants: Female: 71% Males: 29% Leavers: Female 63% Males 37%

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7

Gender Equality Action Plan 2007-2010

Objective 1: Leadership Commitment Actions Outcome measures 1.1 Demonstrate leadership • Improved attendance by commitment at all levels to Diversity Champions at gender equality by: meetings; • Supporting and recognising • Provision of Diversity the work of the Diversity Champion identification Champions through regular (lanyards to denote meetings with priority Diversity Champion); attendance and • Increased awareness acknowledgement in among staff of Diversity Diversity Champions’ Champions and appraisals Harassment Support • Providing training to Workers via staff Harassment Support feedback in Staff Workers on the Gender Survey; Equality Duty • Increased awareness • Recruitment and training of among Harassment volunteer staff as Support Workers on Nominated Persons for the gender equality issues True Vision Hate Crime including transsexual reporting scheme issues in discharging their role, evidenced in training evaluation questionnaire. 1.2 Implement new appraisal New appraisal is scheme with diversity implemented and issues competency measurements arising from appraisals and devise plans to improve relating to diversity diversity competency among competency are managers and team leaders. addressed such as via training. 1.3 Recruit representatives to Improved representation become co-opted members on Equality Working who have specific awareness Group on gender equality in gender equality including issues. transsexual issues

Responsibility Diversity Manager

Timescale September 2008

HR Manager/ Diversity Manager

September 2008

Diversity Manager

December 2007

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Objective 2: Workforce Diversity and Equality Actions Outcome measures 2.1 Implement actions arising Actions implemented. from Staff Survey 2006 as Staff perception and relating to equality and experience improved harassment issues from position in 2006, as evidenced in new survey or staff focus groups. 2.2 Ensuring transsexual staff Information about have access to support support networks networks publicised via intranet 2.3 Present half-yearly Specific strategies employment equality data to developed to address Equality Working Group with any identified pattern recommendations to address of discrimination in any pattern of discrimination or employment practice. equality issue.

Responsibility Timescale ACO/HR July 2008 Manager/Diversity Manager

ACOs/HR Manager/Diversity Manager HR Manager/Diversity Manager

December 2007 December 2007

Objective 3: Equal and Accessible Services Actions Outcome measures 3.1 Implement LGBT • Monitoring system monitoring and ensure that implemented and data collected is returns expected to disseminated regularly reach 60% in the against NPA performance first year of areas implementation. • Performance reports contain analysis of gender and LGBT strands, as well disability and ethnicity. 3.2 Conduct focus groups An action plan with women offenders to developed to address obtain feedback on services issues identified in received and devise actions the focus group. to improve services where needs are identified. 3.3 Implement NPA Policy • Increased on Working with Women awareness of the Offenders: different • Briefing for Managers criminogenic needs of male, female and • Issue practice notes to all transsexual staff offenders • Review policy and practice • Key policy areas relating to women

Responsibility Timescale Diversity Manager via February BPI group 2008 Performance Manager/Information

ACOs/Diversity Manager

December 2007

ACOs/SPOs/Diversity July 2008 Manager

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offenders on Accredited Programmes and develop an action plan.

3.4 Produce NPA procurement policy that sets out gender equality duty as criteria for tenders and contract management. 3.5 Implement Domestic Violence Policy and consider further work with regard to violence against men, transsexuals and violence in same-sex relationships

implemented and accredited programmes reviewed and actions planned. Robust arrangements in contract specifications to ensure legislation compliance. Policy implemented and monitoring procedures in place.

ACO/Procurement Manager

April 2008

SPO Victims and Domestic Violence

May 2008

Objective 4: Community Engagement and Communication Actions Outcome Responsibility measures 4.1 Develop a strategy for Increased range of Diversity community engagement and diverse groups and Manager/ communication with diverse stakeholders for Communications voluntary and community NPA and Officer organisations awareness of needs of specific groups such as transsexual individuals 4.2 Ensure that community Increased range of Diversity engagement activities include diverse groups and Manager/ organisations and voluntary groups stakeholders for Communications who provide services for women NPA and Officer offenders and transsexual people. awareness of needs of specific groups such as transsexual individuals

Timescale December 2007

April 2008

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Objective 5: Legislative Duties Actions 5.1 Ensure that all staff and managers and board members receive training / briefing on the Gender Equality Duty.

5.2 Publish NPA Gender Equality Scheme and receive feedback from partners and stakeholder organisations.

5.3 Review Gender Equality Scheme and Action Plan

Outcome measures Improved awareness at all levels of the organisation of Gender Equality Duty, based on evaluation of training programmes NPA’s commitment and actions are shared with the community to inform review of its Gender Equality Scheme and Action Plan. NPA’s achievements are published and new action plan formulated.

Responsibility Diversity Manager/ Training Manager

Timescale December 2007

Diversity Manager

April 2007

Diversity Manager/HR Manager

April 2008

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Annex A NPA Policy Development Framework and Equality Impact Assessment Process All of NPA’s functions and policies are subject to the process of equality impact assessment. The process is undertaken via the Equality Working Group. A timetable for the assessment of function and policies is drawn up by the Board Secretary and scheduled into the meetings of the Equality Working Group and the Equality Impact Assessment Group. For all policy development and review, policy owners must follow the NPA Framework for Developing Policy, Strategy, Processes and Guidelines. This framework tool acts as a screening process with questions which enable the policy writer to consider the research and evidence (national and local) that are relevant to the proposed policy. The framework also asks for information on stakeholder interest, consultation groups, critical success factors, evaluation method, and potential risks. Policy developers are expected to conduct the necessary consultations with key stakeholder groups to inform the development of the policy. The Framework Document also identifies an implementation plan, evaluation methods, and communication strategy for the policy as well as resource implications such as training needs. In the light of the new Disability Equality Duty, the Framework document will be reviewed to ensure that the concept of inclusive design and the social model are embedded. The Framework template gives guidance for policy developers and contains a diversity impact assessment section. Policy developers are asked to complete this before the policy reaches the Equality Impact Assessment Group which includes 6 co-opted members recruited from local Black and minority ethnic organisations. One of the action areas is to recruit co-opted members from the local disability organisations so that disability issues are fully represented in the assessment process. The co-opted members contribute to the Equality Impact Assessment process by scrutinising the consultation process and monitoring undertaken by the policy developer, and to offer comments and suggestions to ensure that no minority groups will be discriminated against or disadvantaged by the policy. The equality impact assessment process is conducted in the Equality Impact Assessment Sub-Group using the assessment tool – NPA Equality Impact Assessment (Annex B). Any adverse impact or issues arising from this process are communicated to the policy developer for the policy to be revised to address the issues identified. Then the revised policy is re-presented to the Equality Working Group at a future date before its formal approval by the Board. The Equality Working Group meets quarterly preceded by the Equality Impact Assessment Group and acts as the final scrutiny of all NPA policies and functions for equality implications before its final presentation to the Board.

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Annex B Equality Impact Assessment – Questions 1 to 6 - for completion by Policy Developer 1 2 3 4 Is this a new policy? Is this a new function? If this is an existing policy show date of last review Relevance of policy/function to the Public Duty to promote: Race Equality Gender Equality Disability Equlaity Yes/No Yes/No

High/Medium/Low

If you have answered High or Medium to any part in Question 4, please proceed with Assessment If you have anwered Low for all parts of Question 4 – stop here 5 Please state below how the Based on information on the local following groups might be communities, the diversity profiles, affected any specific groups who are likely to be unfairly or adversely affected by this policy: Black & minority ethnic people (including Travellers and Gypsies) Women Men Transgendered people Lesbian and Gay people Disabled people including people with physical or sensory impairments and learning difficulties Older people Young people People of particular faith/s People who have mental health issues People who are of refugee or asylum seeking status

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Any other groups identified? (eg. Unemployed, homeless, literacy level, having caring responsibility)

6

Measuring impact of relevant functions and policies: Is the function/policy subject to equality monitoring? How is the data collected/disseminated? Where will it be discussed? Has the policy developer consulted with any groups or sought information from them? Yes/No

Yes/No (Please state)

For completion by Equality Impact Assessment Group: 7 Other diversity observations: Language Format Does the policy follow NPA’s Accessibility Guidelines? 8 Changes proposed for the policy developer: Yes/no

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