The guidance and examples on this page are part of a set of guidance designed to support you in completing an Equality Impact Assessment (EIA) template.
Please visit the Equality Impact Assessment webpage for more information.
Guidance for Question 7:
Based on the analysis of your evidence, if you identify any negative impacts, you will need to act to mitigate this. Ask yourself:
- What is causing the negative impact?
- Are there any alternative measures or interventions that would achieve the intended aims of the practice without having a negative effect?
- Are there any additional measures which would further equality of opportunity in the context of this practice?
To address identified negative impacts, consider the following options:
- When considering the impacts of proposed practices on groups of people, it could be necessary to adjust the practice to eliminate a negative impact, or to ensure a more targeted (and proportionate) approach to the issues to be addressed, leading to better outcomes. (See example)
- Implement support systems like training programs, communications or additional resources for affected groups.
- Engage staff from different groups to refine mitigation strategies through dialogue and feedback.
- Establish robust monitoring mechanisms to track effectiveness, regularly reviewing and adjusting measures based on feedback.
- Clearly document and communicate mitigation strategies to relevant stakeholders, fostering transparency and accountability.
Example: Adjustments to practice
The University considers mandating EDI training for all staff with the aim that it will promote equality of opportunity and foster good relations through improved understanding, inclusion and support for diverse groups. However, it recognises that mandating the training for everyone may be met with resistance, may not be wholly relevant to everyone, or may not effectively address all or specific diversity-related issues. Consequently, it may not meet the aims of PSED in relation to people with protected characteristics.
• Initially, the University may consider piloting training in an area which shows most or relevant need.
• Training is developed that is specific to challenges faced by students or staff (evidence-based), eg, unconscious bias in hiring or grading or supporting students’ diverse needs.
• Voluntary components are available to staff who wish to enhance their learning
• The impact of the pilot and mandatory component is evaluated for impact to inform further implementation, and to ensure that it remains relevant and effective.
When negative impacts persist (or later become apparent through monitoring) despite mitigation efforts:
- Clearly define aspects of the practice causing negative impacts and understand how they affect different groups.
- Engage with stakeholders to gather further insights on minimising negative impacts.
- Explore alternative approaches, assessing feasibility, benefits, and drawbacks.
- Based on stakeholder input, review whether the practice could be redesigned, to further mitigate the negative impact and still gain the benefits of the legitimate aim(s).
- Consider whether positive action is relevant and appropriate in this situation.
- Carefully plan and implement changes, providing necessary support and resources for impacted groups.
- Continuously monitor impact, collect feedback, and adjust the practice as needed.
- Document decision-making, changes made, and rationale to maintain transparency and accountability.
Examples: Mitigations
These example mitigations relate to the examples of negative impacts within the guidance for Question 6:
a) Ensuring that all renovations include accessibility features and consultation with disability advocates during the planning process.
b) Including diverse cultural events representing various racial and ethnic groups
c) Implementing policies that recognise and respect correct names and pronouns
d) Offering training sessions for older employees and others on digital communication tools
e) Creating gender-inclusive scholarship opportunities
f) Modifying dress code policies to accommodate the needs of people of different religions, disabled people, people of different genders or another protected characteristic.
There may be cases where a negative equality impact is justifiable, for example:
- to address the needs of a particular group through positive action
- for business delivery reasons
- for health and safety reasons
- for security reasons
If you believe that a negative impact on a particular group may be justified, please liaise with your EDI lead, or the EDU. It must be explicit why this is the case.
Once you have mitigated any negative impacts, and maximised opportunities to advance equality, you should be in a position to make an informed judgement about what should be done with your policy. This decision should be made within the relevant governance processes.
- No major change to practice – analysis demonstrates that the practice is robust, remember to document the reasons for this and how this decision was made.
- Adjust the practice – remove barriers or to put in place actions identified as part of the analysis exercise.
- Implement the practice with actions to address negative impacts
- Do not continue with the practice
