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Norfolk Probation Area

Disability Equality Scheme


2006-2009
Contents

1 Introduction by Martin Graham, Chief Officer

2 General introduction of the Disability Equality Scheme


2.1 Aims and Objectives
2.2 Values and Commitment to Diversity
2.3 The NPA Disability Equality Scheme
2.4 Involvement of Disabled People
2.5 Implementing the Scheme

3 Duties under the Disability Discrimination Act


3.1 General Duties
3.2 Specific Duties

4 Key challenges on disability equality


4.1 National Challenges
4.2 Local Challenges

5 Outcomes of NPA Disability Equality Scheme

6 Process and arrangements for delivering our specific duties


6.1 Accessibility Plan
6.2 Impact Assessment of Policies
6.3 Leadership
6.4 Involvement and Community Engagement
6.5 Communication and Information
6.6 Services for Offenders and Victims
6.7 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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1 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 General Introduction to the Disability Equality Scheme

2.1 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

2.3 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

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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.

2.5 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.

3 Duties under the Disability Discrimination Act

3.1 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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• 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, rights-
based approach to service provision. NCODP has provided an advisory role

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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 pre-
employment 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)

4 Key Challenges on Disability Equality

4.1 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.

4.2 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.

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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

5 Outcomes of the NPA Disability Equality Scheme

5.1 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:

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• 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

6 Delivering our Specific Duties

6.1 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

19
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

20
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.

21
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.

22
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

24
Annex B: Disability Equality Action Plan (January to December 2007)

Disability Equality Objective 1:


Leadership Commitment
Relevance to General Duty of Disability High
Equality
Lead Responsibility ACO (Support Services)
Organisational Risk High
Cross Reference with Diversity Action Plan
Timescale for actions under Objective 1 December 2007

Actions Outcome Measures Lead


Responsibility
1.1 Demonstrate leadership Increased visibility and Diversity Manager
commitment at all levels to disability recognition of Diversity
equality by: Champions.
• Supporting and recognising the Disabled staff have information
work of the Diversity Champions about support networks and are
• Ensuring disabled staff have encouraged to participate by
access to support networks managers.
• Providing training to Harassment Increased awareness among
Support workers on Disability Harassment Support workers on
Discrimination Act 2005 disability discrimination in
discharging their role, evidenced
in evaluation questionnaire.
1.2 Managers and team leaders Increased awareness among ACOs/SPOs/OSMs
demonstrate diversity competency in leaders at all levels on diversity
team management and offender issues, as evidenced in
management supervision, appraisals and
performance reports.
Observable difference in team
ethos and settings, as evidenced
in staff surveys and focus
groups.
1.3 Recruit representatives from Improved representation on Diversity Manager
disability organisations and Equality Working Group on
communities as co-opted members disability issues
on the Equality Working Group

Disability Equality Objective 2:


Workforce Diversity and Equality
Relevance to General Duty of Disability High
Equality
Lead Responsibility ACO (Support Services)
Organisational Risk High
Cross Reference with Diversity Action Plan
Timescale for actions under Objective 2 December 2007

25
Actions Outcome Measures Lead
Responsibility
2.1 Set local target and devise Local target for disability HR Manager
recruitment procedures that reach recruitment met or showing
disabled communities to continue to improvement.
develop a skilled and diverse
workforce.
2.2 Monitor the harassment support Reduction of grievance and HR Manager
scheme to identify any pattern of disciplinary cases relating to /Diversity
harassment or bullying based on harassment. Staff perception of a Manager
specific social identity groups safer and more harmonious
including disabled staff working environment, as
evidenced in staff surveys and
focus groups.
2.3 Participate in future programmes Improved representation at SMT HR Manager
of ‘Accelerate’ by NPD that target level of disabled people.
disabled staff into senior management
2.4 Develop a diversity competency Increased diversity awareness and HR Manager /
framework (including disability issues) competency among staff at all Diversity
to be integrated into job descriptions levels of roles and responsibilities, Manager
and person specification and used for as evidenced in supervision,
the purposes of assessments, appraisals and performance
performance management, training reports.
and development.
2.5 Ensure provision and support for Improved performance and morale IT Manager/
disabled staff who use Assistive among disabled staff, as Occupational
Technology evidenced in staff Health Manager
consultation/focus groups.

Disability Equality Objective 3:


Equal and accessible services
Relevance to General Duty of Disability High
Equality
Lead Responsibility ACO (Support Services)
Organisational Risk High
Cross Reference with Diversity Action Plan
Timescale for actions under Objective 3 December 2007

Actions Outcome Measures Lead


Responsibility
3.1 Improve on disability monitoring Percentage of disability monitoring All ACOs
and ensure that data collected is improved from 70% missing data.
disseminated regularly to assess if Improved satisfaction among
reasonable adjustments are disabled service users, assessed
implemented and effective. via focus groups, complaints or
satisfaction survey.
3.2 Develop action plan arising from An integrated approach to Diversity
Offender Satisfaction Survey in addressing disability issues with Manager
September 2006 to address disability performance outcomes that are

26
issues highlighted in the report measurable.
3.3 Undertake an audit of victim Increased awareness of disability Diversity
support work on disability issues and issues in victim support work and Manager
devise actions to address any barriers an action plan with performance
to services outcomes that are measurable.
3.4 Publish a timetable for the An integrated approach to the Diversity
assessment of functions and policies assessment of functions and Manager
for the purpose of the Disability demonstrates compliance with the
Equality Scheme Disability Equality Duty.
3.5 Develop a policy on procurement A policy that meets the ACO
identifying processes for the requirements of the new Duty and (Interventions)/
assessment of contractors in meeting ensures that disabled service Diversity
the Disability Equality Duty. users have access to high quality Manager
services and developed with
stakeholder involvement.
3.6 Develop Accessibility Plan for Accessibility Plan and strategies Diversity
NPA based on report by NPD of developed and agreed with NOMS. Manager and
premises audit and strategies for Health and
bidding with NOMS for implementation Safety Manager
of plan
3.7 Develop a policy and guidance on Policy and guidance implemented. Unpaid Work
Unpaid Work in respect of disabled Manager and
offenders Diversity
Manager
3.8 Improve diversity practice in Court procedures reflect diversity Diversity
partnership working including court practice following equality impact Manager/ACOs
procedures to ensure that staff and assessment.
offenders are not discriminated on the
ground of disability.

Disability Equality Objective 4:


Community engagement and
communication
Relevance to General Duty of Disability High
Equality
Lead Responsibility ACO (Support Services)
Organisational Risk High
Cross Reference with Diversity Action Plan
Timescale for actions under Objective 4 December 2007

Actions Outcome Measures Lead


Responsibility
4.1 Develop a strategy for A consultation mechanism that HR Manager
engagement and communication with meets the requirements of the
local disability organisations. Disability Equality Duty.
4.2 Ensure that our communication Improved channels of Diversity
methods are accessible by disabled communication with disabled staff Manager
staff and disabled service users, using and service users, based on
information based on consultations follow-up feedback from staff and

27
undertaken as part of this Scheme. service users.
4.3 Ensure that our community Improvement involvement of Diversity
engagement programmes include disability organisations in NPA Manager /
organisations and voluntary groups for business and policy making Communication
disability. processes, based on number of Officer
contacts made and programme
participation.

Disability Equality Objective 5:


Legislative duties
Relevance to General Duty of Disability High
Equality
Lead Responsibility ACO (Support Services)
Organisational Risk High
Cross Reference with Diversity Action Plan
Timescale for actions under Objective 5 December 2007

Actions Outcome Measures Lead


Responsibility
5.1 Ensure that all staff and managers Improved awareness at all levels Diversity
and board members receive training / of the organisation of Disability Manager/
briefing on the Disability Equality Duty, based on evaluation Training
Discrimination Act and the Disability of training programmes. Manager
Equality Duty.
5.2 Undertake audit of NPA NPA procedures for equality Diversity
procedures for equality impact impact assessment include Manager
assessment and ensure that disability disability equality issues and are
equality issues are assessed and compliant with legislation.
comply with legislation.
5.3 Publish Disability Equality Scheme NPA’s commitment and actions Diversity
and receive feedback from partners are shared with the community to Manager
and stakeholder organisations inform review of DES and Action
Plan.

28
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 re-
presented 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.

29
Norfolk Probation Area
Equality Impact Assessment template

1 Is this a new policy? Yes/No


2 Is this a new function? Yes/No
3 If this is an existing policy show date of last
review
4a Is the policy/function relevant to the Public Yes/No
Duty to promote good race relations :

4b Is the policy/function relevant to the Public Yes/No


Duty to promote disability equality?

4c Is the policy/function relevant to the Public Yes/No


Duty to promote gender equality?

4d Is the policy/function relevant to the


promotion of good practice in other diversity
fields

If the answer to 4a, 4b, 4c and 4d is No – stop here!


If Yes to either – please proceed with Assessment
5 Based on information on the local Please state below how the
communities, the diversity profiles, following groups might be
any specific groups who are likely to affected
be unfairly or adversely affected by
this policy due to:

Race/nationality

Gender

Sexual Orientation

Belief

Disability –
i. Physical

ii. learning difficulties

iii. sensory

Age

30
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 Yes/No


monitoring?
How is the data collected/disseminated?
Where will it be discussed?

Has the policy developer consulted with Yes/No


any groups or sought information from
them?
7 Other diversity observations:

Language

Format

Does the policy follow NPA’s Accessibility


Guidelines?

8 Changes proposed for the policy Yes/no


developer:

31
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

32
• 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.

33
Annex E: Comment form

Please answer the following questions by putting a circle on your responses:

1 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:

2 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:

3 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:

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.

34
Annex F: Glossary

ACO Assistant Chief Officer


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

35
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

3
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.

6
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.

7
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).

8
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).

9
3. Leadership

10
• 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 co-
opted 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.

12
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.

13
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.

14
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.

15
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.

16
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.

17
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.

18
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%

19
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.

20
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.

21
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)

22
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.

23
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.

24
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

25
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)

27
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

28
Norfolk Probation Area
Gender Equality Scheme
2007-2010
Contents

1 Introduction by Martin Graham, Chief Officer

2 General introduction of the Gender Equality Scheme


2.1 Norfolk Probation Area
2.2 Aims and Objectives
2.3 Values and Commitment to Diversity

3 Duties under the Gender Equality Act 2006


3.1 General Duties
3.2 Specific Duties
3.3 Duties for Transsexual People
3.4 Duty to Eliminate Harassment

4 Key Priorities and Outcomes of the Scheme

5 Gender Equality and Service Delivery

6 Gender Equality and Employment

7 Gender Equality Action Plan 2007-2010

Annex A NPA Policy Development Framework

Annex B 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

2
1 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

3
2 General Introduction of the Gender Equality Scheme

2.1 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:

ƒ Protecting the public


ƒ Reducing re-offending
ƒ Ensuring the proper punishment of offenders in the community
ƒ Ensuring offenders’ awareness of the effects of crime on the victims
of crime and the public
ƒ Rehabilitation of offenders

The establishment of NOMS provides a new context for work with


offenders which provides:

ƒ A focus on offender management with a single offender manager


responsible for assessing need, selecting and sequencing
interventions;
ƒ The use of commissioning to separate the identification of need
from the delivery of services;
ƒ 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:

ƒ Offender Management which holds offenders to account but


recognises the value of each individual and their capacity to
change;

ƒ Interventions which meet the identified criminogenic needs of


offenders delivered both in-house and in partnership with a range of
voluntary and private organisations;

ƒ Protection for the public of Norfolk by close inter-agency working


with other organisations within the Criminal Justice System;

ƒ Re-assurance for victims of crime through the reduction of re-


offending and the effective management of offenders;

ƒ Development and training opportunities for staff which enable them


to be properly skilled to carry out their different roles within NPA;

ƒ A safe and healthy working environment which promotes the


development of individuals’ potential;

4
ƒ 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:

ƒ Leadership Commitment
ƒ Workforce diversity and Equality
ƒ Equal and Accessible services
ƒ Community engagement and communication, and
ƒ Legislative duties

5
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:

ƒ Eliminate unlawful discrimination


ƒ Eliminate harassment
ƒ 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:

ƒ Prepare and publish a Gender Equality Scheme

ƒ Include objectives to address the causes of any gender pay gap

ƒ Gather and use information on how NPA’s policies affect gender equality
in the workplace and in the delivery of services

ƒ Consult stakeholders (employees, service users and partners) to


determine its gender equality objectives

ƒ Assess the impact of current and proposed policies and practices on


gender equality

ƒ Implement the actions set out in this scheme

ƒ 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,

6
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.

(iii) 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:

ƒ Grade
ƒ Job application and appointment
ƒ Career Progression
ƒ Grievance procedures
ƒ Disciplinary procedures
ƒ Harassment cases
ƒ Performance appraisal procedures
ƒ 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:

7
ƒ Risk of harm
ƒ Rescores of OASys to assess changes in risk levels at
the end of supervision
ƒ Tracking reports to demonstrate consistency (undertaken
by Offender Managers)
ƒ Results of psychometric testing for offenders undertaking
programme
ƒ Post programme reports

The following performance areas are also subject to diversity


monitoring including gender monitoring:

ƒ Breaches
ƒ Compliance
ƒ Concordance
ƒ Programme completions
ƒ Unpaid Work completions
ƒ Victim contact
ƒ Accommodation
ƒ Skills for life
ƒ 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

8
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:

ƒ 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).

ƒ All policies are presented to the Equality Impact Assessment Group


which comprises officers and co-opted members representing a

9
diverse range of equality and diversity issues from the community.

ƒ 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.

ƒ The Equality Working Group maintains a prioritised list of functions and


policies and a timetable for the regular review of these functions and
policies.

ƒ The prioritisation of functions and policies is guided by national


priorities and are assessed in terms of their relevance to the Gender
Equality Duty.

ƒ NPA is committed to undertake the statutory 3-year gender equality


review of our functions and policies and new policies.

ƒ All NPA policy documents show date of origination of policy and review
dates as well as the name of the policy developer.

ƒ All policies which have been impact assessed are recorded in the
minutes of the Equality Working Group and available on the intranet.

ƒ 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:
ƒ Leadership
ƒ Workforce Diversity and Equality
ƒ Equal and Accessible Services
ƒ Community Engagement and Communication
ƒ 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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ƒ Monthly review by ACO (Support Services) and Diversity
Manager during monthly supervision meetings

ƒ NPA’s Equality Working Group which meets bi-monthly

ƒ Half yearly reports of Diversity Action Plan to the Equality


Working Group and the Board.

ƒ 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:-


ƒ promote awareness amongst staff of the different forms that
harassment and bullying may take
ƒ inform staff at all levels of the organisation of their
responsibilities to ensure that the working environment is free
from oppressive behaviour
ƒ 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:

11
ƒ Sexual harassment
ƒ Racial harassment
ƒ Harassment of people with disabilities or learning difficulties
ƒ Harassment of lesbians, gay men and bisexuals
ƒ Harassment of transgendered and transsexual individuals
ƒ 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.

12
4 Key Priorities and Outcomes of this Scheme

4.1 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:

ƒ Implementation of the Domestic Violence Policy

ƒ Implementation of the Women Offenders Policy

ƒ Implementation of the True Vision third party reporting for


Hate Crime

ƒ Implementation of the Procurement Policy that integrates


diversity into its tender and contract arrangements

ƒ 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.

4.3 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:
ƒ 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.
ƒ Managers and team leaders to demonstrate diversity
competency in team management and offender management,
assessed via the performance appraisal system
ƒ The Equality Working Group to have representation on gender
and LGBT issues, particularly at co-opted member level

Workforce Diversity and Equality:


ƒ Access to support networks for transsexual staff
ƒ Harassment Support Workers to receive training in supporting
all minority staff groups
ƒ Review of recruitment procedures to eliminate any gender bias

Equal and Accessible Services:


ƒ Accessible services which take account of the different
criminogenic needs of male and female offenders
ƒ NPA’s performance areas will be scrutinised by gender issues

13
ƒ A timetable for the assessment of functions and policies will be
published for the first year of the Scheme
ƒ 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
ƒ Implementation of NPA Domestic Violence Policy
ƒ Implementation of NPA Women Offenders’ Policy
ƒ Review of provisions for women on accredited programmes to
be undertaken and outcome actions prioritised

Community Engagement and Communication:


ƒ A strategy for engagement and communication with local
organisations to be developed
ƒ NPA community engagement programmes to include
organisations and voluntary groups providing services for
women offenders

Legislative Duties:
ƒ All staff and managers to have received training or briefing on
the Gender Equality Duty
ƒ All Board Members including co-opted members to have
received training or briefing on the Gender Equality Duty
ƒ NPA procedures for equality impact assessment will include
gender equality and comply with the Equality Act 2006
ƒ New Gender Equality Scheme published

14
5 Gender and Service Delivery – Equal outcomes, different
approaches

5.1 Male and Female Offenders

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:

ƒ 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.

15
o Assessment
o Sentence Planning
o Evaluation
ƒ Mentoring
ƒ Interventions:
o Unpaid Work requirements
o Accredited programmes
o Employment programmes

Other support services to assist rehabilitation and resettlement include:

ƒ Accommodation
ƒ Drug and alcohol treatment
ƒ Literacy and numeracy skills
ƒ Approved premises
ƒ Health and mental health
ƒ Support for children and families
ƒ Debt and Finance advice
ƒ Education and Training
ƒ 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.

16
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.

17
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 Percentage


Women 209 67%
Men 105 33%

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)

Job Groups Women % of % of All Men % of % of All


total in Females total in Males
Group Group
Management 20 57% 9% 15 42.8% 16%
Operational/Practitioner 124 65.3% 56% 66 34.7% 71%
Administrative/Specialist 73 86.9% 33% 11 13.1% 11.8%
Secondments 4 80% 1.8% 1 20% 1%
Total 221 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 Staff Working Patterns (as at March 2007)

(i) Part-time working

Women Men
Full-time 154 91
Part-time 53 14
% of all part-time posts 79% 20.8%
% of total women/men 24% 15%

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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 over-
representation 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:
ƒ job-share – where one job is split between 2 individuals on shared
arrangements
ƒ fixed-term contract – where the contract is set up for a fixed period.
ƒ consolidated hours – where full time hours are worked in 4 longer days
instead of 5 days
ƒ 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
ƒ 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:

ƒ Compassionate/bereavement leave
ƒ Dependants’/carers’ leave
ƒ Leave for domestic emergencies
ƒ Religious observance
ƒ Medical or dental appointments, including fertility treatment and
blood/bone marrow donation
ƒ Study leave

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ƒ Leave for child’s first day at school
ƒ Extended annual leave
ƒ Jury service or court/tribunal attendance
ƒ Leave for adjustment to disability
ƒ 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:
ƒ Maternity or adoption leave
ƒ Parental or special leave
ƒ Fertility treatment
ƒ Antenatal care
ƒ 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 Responsibility Timescale
1.1 Demonstrate leadership • Improved attendance by Diversity September
commitment at all levels to Diversity Champions at Manager 2008
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 HR Manager/ September
scheme with diversity implemented and issues Diversity 2008
competency measurements arising from appraisals Manager
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 Diversity December
become co-opted members on Equality Working Manager 2007
who have specific awareness Group on gender equality
in gender equality including issues.
transsexual issues

21
Objective 2: Workforce Diversity and Equality
Actions Outcome measures Responsibility Timescale
2.1 Implement actions arising Actions implemented. ACO/HR July 2008
from Staff Survey 2006 as Staff perception and Manager/Diversity
relating to equality and experience improved Manager
harassment issues from position in 2006,
as evidenced in new
survey or staff focus
groups.
2.2 Ensuring transsexual staff Information about ACOs/HR December
have access to support support networks Manager/Diversity 2007
networks publicised via intranet Manager
2.3 Present half-yearly Specific strategies HR December
employment equality data to developed to address Manager/Diversity 2007
Equality Working Group with any identified pattern Manager
recommendations to address of discrimination in
any pattern of discrimination or employment practice.
equality issue.

Objective 3: Equal and Accessible Services


Actions Outcome measures Responsibility Timescale
3.1 Implement LGBT • Monitoring system Diversity Manager via February
monitoring and ensure that implemented and BPI group 2008
data collected is returns expected to Performance
disseminated regularly reach 60% in the Manager/Information
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 ACOs/Diversity December
with women offenders to developed to address Manager 2007
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 ACOs/SPOs/Diversity July 2008
on Working with Women awareness of the Manager
Offenders: different
• Briefing for Managers criminogenic needs
• Issue practice notes to all of male, female and
staff transsexual
• Review policy and practice offenders
relating to women • Key policy areas

22
offenders on Accredited implemented and
Programmes and develop accredited
an action plan. programmes
reviewed and
actions planned.
3.4 Produce NPA Robust arrangements ACO/Procurement April 2008
procurement policy that sets in contract Manager
out gender equality duty as specifications to
criteria for tenders and ensure legislation
contract management. compliance.
3.5 Implement Domestic Policy implemented SPO Victims and May 2008
Violence Policy and consider and monitoring Domestic Violence
further work with regard to procedures in place.
violence against men,
transsexuals and
violence in same-sex
relationships

Objective 4: Community Engagement and Communication


Actions Outcome Responsibility Timescale
measures
4.1 Develop a strategy for Increased range of Diversity December
community engagement and diverse groups and Manager/ 2007
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 April 2008
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

23
Objective 5: Legislative Duties
Actions Outcome Responsibility Timescale
measures
5.1 Ensure that all staff and Improved Diversity December
managers and board members awareness at all Manager/ 2007
receive training / briefing on the levels of the Training
Gender Equality Duty. organisation of Manager
Gender Equality
Duty, based on
evaluation of
training
programmes
5.2 Publish NPA Gender Equality NPA’s commitment Diversity April 2007
Scheme and receive feedback from and actions are Manager
partners and stakeholder shared with the
organisations. community to inform
review of its Gender
Equality Scheme
and Action Plan.
5.3 Review Gender Equality NPA’s Diversity April 2008
Scheme and Action Plan achievements are Manager/HR
published and new Manager
action plan
formulated.

24
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.

25
Annex B
Equality Impact Assessment –
Questions 1 to 6 - for completion by Policy Developer

1 Is this a new policy? Yes/No


2 Is this a new function? Yes/No
3 If this is an existing policy show date of last
review
4 Relevance of policy/function to the Public High/Medium/Low
Duty to promote:
ƒ Race Equality
ƒ Gender Equality
ƒ Disability Equlaity

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 Based on information on the local Please state below how the
communities, the diversity profiles, following groups might be
any specific groups who are likely to affected
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

26
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 Yes/No


monitoring?
How is the data collected/disseminated?
Where will it be discussed?

Has the policy developer consulted with Yes/No (Please state)


any groups or sought information from
them?

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 Yes/no


developer:

27
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