Appendix D Summary: Equality and Human Rights Impact Assessment (EqHRIA)

a. Background:
Police Scotland are required by legislation to assess and review the equality impact of policies and practices, and to publish a summary of the results.

EqHRIA has been developed as an evidence-based tool to assess the potential impact of policies and practices on equalities and human rights. Police Scotland requires an EqHRIA to be completed for any new policy or practice or any policy or practice undergoing review. There is a standard template in place which is to be used for all EqHRIAs to ensure a consistent and thorough approach to assessment.

b. Internal Audit Findings:
BDO was able to provide limited assurance over the design and the operational effectiveness of controls in place.

Two high risk issues were raised related to clarity of EqHRIA requirement and completion in line with guidance. The audit found that the EqHRIA template largely aligns with standard practice, however, guidance does not clearly define the criteria that would trigger the need for an EqHRIA or specify at what stage it should be completed. The audit found this lack of clarity has led to inconsistencies, with some business cases not having EqHRIAs completed. There are also issues with the completion of EqHRIA’s in line with guidance.

Further medium risks findings related to a: lack of training, storage, action monitoring, quality assurance, reporting to SPA and change project reporting.

c. Summary of Findings of the Report:
SUMMARY OF FINDINGS/AGREED ACTIONS
High 2/6
Medium 6/10
Low 1/2
TOTAL: 9/18

d. SPA Considerations:
The report demonstrates that a number of improvements are required. Police Scotland was aware of weaknesses in this area and proactively sought an internal audit. This demonstrates a mature approach to continuous improvement.

In this case Police Scotland, in addition to accepting and responding to all recommendations, has provided the following addition overarching management response:

We acknowledge there are some inconsistencies in practice across Police Scotland. We have some very good processes in place across our People and Development structure relating to staffing procedures and as part of our National Record Set but recognise that these same structures should apply to all we do. It has been a challenge to achieve this same consistency across the whole of Police Scotland in relation to service delivery due to the wide range of services impacted and number of different teams involved.

Recognising the need for improvement, Police Scotland requested this audit be undertaken and in advance established an EHQRIA Improvement Group to set out making the necessary changes to ensure our legal obligations are met in the most effective and efficient way. The group are leading on improvements relating to the Police Scotland document set, our governance processes, our processes including centralised storage and tracking, communications, training, and organisational learning. We are taking a structured approach to this improvement and have full representation across a wide range of areas as this extends to all areas of policing. We are also securing additional police staff resource on a fixed term contract to support the changes we need to make.

We also commissioned an independent review to establish a Human Rights Baseline Assessment. The findings from this assessment along with recommendations from the Independent Review Group and HMICS Organisational Culture Assurance Review are being considered to ensure a holistic approach to improvement is undertaken with EqHRIA at the heart of our decision making processes.”