Step 1– scoping the equality impact assessment (EIA)
1.1. Name of the strategy / policy / procedure / practice
- Corporate Debt Recovery Policy
1.2. What are the main aims, purpose and outcomes of policy and how does it fit in with the wider aims of the organisation?
The Policy sets out how the council will approach debt recovery, having regard to minimising arrears whilst at the same time not causing undue hardship or consequences to the debtor as a result of the overall approach to a multiple debt.
The council also has wide ranging social responsibilities. It is not possible to have one standard approach for the recovery of all types of debt, and specific arrangements are required tomake sure all client groups are dealt with fairly and appropriately, putting the customer at the centre, taking into consideration the reasons for the debt and whether this relates to any of the protected characteristics in the new Equality Act e.g. disabled people may face greater barriers to employment and therefore an ability to generate a regular income.
- to protect financial well being and reputation of the council,
- to promote financial equality,
- to manage debt promptly,
- to work as a unified authority across the organisation and consider all debts due, and
- provide signposting for our customers to appropriate support and advice which is fully accessible.
1.3. List the main activities relating to the policy and identify who is likely to benefit from it
The council raises a significant proportion of its total income through local taxes and charges and it is essential that every effort is made to recover all amounts due to it. This will make sure our income is kept at an optimum to make sure the overall cost of services delivered and tax increases are kept to the lowest possible for the community as a whole. To protect those who do provide regular and prompt payment.
The process for some of the Councils activities are governed by statue (Council Tax and non-domestic rate recovery and rent arrears), but where a debt is not related to these areas, other processes are in place to follow. These processes are also dependant on the category of debt as the council has a social responsibility towards the vulnerable or disadvantaged groups and cannot have a single uniform policy to cover all activities. Specific guidance will be developed to meet the needs of disadvantaged groups, once it is established how those groups are impacted by debt.
All parties will benefit from the policy – The council and its officers, partner organisations including Citizens Advice Bureau, and service users, debtors and their advisors. A key part of this is to make sure that we enable our customer in finding the correct advice and support to assist them managing their debt which is appropriate to their needs.
What do you already know about the relevance of the policy? What are the main issues you need to consider?
- All members of the community will need to have the same access and understanding of the debt recovery policy. There may be a need to make sure we can provide the policy in other formats/languages as required. The policy will also be available on the Wiltshire Website.
- The policy includes a written reminders and follow up letters, however if customers have a visual disability access to reading letters may mean that they cannot comply with the policy, this may need to be consider on a case by case approach once customers with this need are identified. Also customers may have English as a second language so all written communication should be in plain English and alternative languages/access to interpreter support available as required to include the needs of British Sign Language users. Note any telephone support should also have a textphone facility for customers who are deaf or hard of hearing.
- Customers from all groups of society could find themselves in a position of financial hardship, therefore each case will need to be looked at on its own merits this will encompass their individual needs including reference to the protected characteristics of the Equality Act.
1.4. What data, research and other evidence or information is available which will be relevant to this EIA?
- The Experian Mosaic
- Joint Strategic Needs Assessment
- Local Agreement for Wiltshire
- Community Plan
- Data from voluntary sector including Citizens Advice Bureau , and Wiltshire Money
- Equality monitoring and data will be gathered from the work of the Debt Management Team, in terms of clients managed to establish any trends or groups or appear to be disadvantaged through the process of debt recovery. The Corporate Equality and Diversity team are currently working on standard guidance.
1.5. What further data or information do you need to carry out the assessment?
We have no clear evidence other than at departmental level, the solution is to revisit this Equalities Impact Assessment after 24 months to make sure we are continuing to make sure the most vulnerable people have the appropriate level of support.
When we have a clearer picture of the who is being adversely affected we can amend the policy as is required – see above re: equality monitoring
Step 2 – Involvement, Consultation and Partnerships
2.1.
| Equality target group | Briefly describe what you did and with whom |
|---|---|
| Other | Consulted those subject to financial exclusion |
2.2. If consultation and involvement of specific groups did not take place, please state why
The financially excluded could come from any group within the community and therefore we the following were consulted
- Citizens Advice Bureau
- Wiltshire Money
- Wiltshire Assembly
2.3. What do previous consultations show about the potential take-up of any resulting activities or services?
The Citizens Advice Bureau and Wiltshire Money expect Wiltshire Council to have an approach to debt management that is consistent across the organisation, and part of this approach will be to get more accurate data on the causes and impact of debt on individuals and the community.
2.4. How are external partners involved, or how do you are intend to involve external partners, in delivering the aims of this strategy / policy / procedure / practice? (if applicable)
Through Wiltshire Money
Step 3 – data collection and evidence
3.1. What evidence or information do you already have about how this policy might affect equality, and what does this tell you?
Each department has an idea of the customers who are subject to recovery proceedings, e.g. in council tax 8000 individuals are subject to court proceeding each year, however this information should be shared across the organisation. Currently we are not able to disaggregate information by personal characteristics, this policy therefore is required to make sure a consistent approach as one Council, to recognise the fact that we create a variety of debt and through the debt management team, gather and monitor data to disaggregate and identify patterns which can fed back into the redesign of processes, and to avoid debt in the first place.
3.2. What does available data tell you about the potential take-up of any resulting activities or services?
Until the policy is adopted and we have a cross departmental approach, data will not be readily available. However as stated precious the plan is to revisit not only the Equalities Impact Assessment but also if required the policy itself.
3.3. What additional research or data is required to fill any gaps in your understanding of the potential or known effects of the strategy / policy / procedure / practice? Have you considered commissioning new data or research?
Data and knowledge regarding personal characteristics should be more readily exchanged so that staff are aware of specific access and other needs.
Step 4 – Assessing impact and strengthening the strategy / policy / procedure / practice
4.1. How does/will the policy and resulting activities affect different communities and groups?
- The policy encourages its recovery staff to consider all debts owed to the organisation which will enable them to more easily identify customers facing a genuine hardship. Indentifying these customers will mean that they can be guided to the appropriate help and guidance to make sure a holistic approach to debt management.
- This should not preclude Wiltshire Council from taking a robust approach where there is found to be an ability to pay.
- Best Practice in other authorities i.e. Shropshire Council, has been considered. There are also further examples of other authorities adopting approaches to combat not only financial exclusion but also Financial Awareness
4.2. What measures does, or could, the policy include to help promote equality of opportunity?
The provision of accessible information in plain English, alternative formats and languages.
The provision of accessible advice and guidance from staff who are trained in Equality and Diversity with appropriate additional support provided as required e.g. interpreters.
The development of preventative measures e.g. support to avoid similar debt occurring in future
4.3. What measures does, or could, the policy include to address existing patterns of discrimination, harassment or disproportionally?
Flexible approach to take into account the needs of disadvantaged groups/individuals
4.4. What impact will the policy have on promoting good relations and wider community cohesion?
By working as one, a debt in one part of the organisation does not create larger debt to another part of the organisation. For example; we would aim to minimise eviction as a result of rent arrears.
Customer at the centre and working with them to make sure they are equipped to mange their debt with the appropriate level of 3rd party support
4.5. If the policy is likely to have a negative effect (‘adverse impact’), what are the reasons for this?
Whilst the council must follow statutory guidelines to secure debt, once debt is secure, this policy should help reduce adverse impact on those suffering financial exclusion.
4.6. What practical changes will help reduce any adverse impact on particular groups?
The creation of a Debt Management Team and cross departmental working. The team must include the voluntary sector and include advocates for those suffering financial exclusion.
We are going to try to create the opportunity to raise the voice of those with a disability and consider the role of an Equality and Diversity champion who can highlight the needs of other disadvantaged groups.
4.7. What evidence is there that actions to address any negative effects on one area of equality may affect other areas of equality or human rights?
A lack of effective approach to debt management has a wider impact on the whole community who could meet the short fall.
4.8. What will be done to improve access to, and take-up of, services or understanding of the policy?
- The wire
- Local strategic partnerships
- Wiltshire Money
- Citizens Advice Bureau
- See also 4.2
Step 5 – making a decision
6.1. Summarise your findings and give an overview of whether the policy will meet the Council’s responsibilities in relation to equality and human rights
We will collect data and review the policy and approach after 24 months in conjunction with the financial evidence and other debt recovery markers
6.2. What practical actions do you recommend to reduce, justify or remove any adverse / negative impact?
- Creation of the team /panel and involvement of the voluntary sector should overcome any negative impact
- Regular monitoring to make sure adoption of the policy within the organisation
- Monitoring of use of the team / Panel
- Monitoring of debt recovery rates by use of aged debt reports and other debt management markers
- Monitoring of debt on a geographical basis (ward or parish)in order to direct resources, training and learning and overlay findings with other information (e.g. Mosaic)
Step 7 – monitoring, evaluating and reviewing
7.1. How will the recommendations of this assessment be built into wider planning and review processes?
Data collected from the panels maybe distributed to a variety of other organisations to assist in future policy making and targeting resources.
Once we have data wee can revisit both the Policy and Equalities Impact Assessment to make sure the most vulnerable people with Wiltshire are not subject to financial exclusion
7.2. How will you monitor the impact and effectiveness of the policy?
- Review of Policy and Equalities Impact Assessment
- Financial data
- Recovery rates
- Aged debt analysis
- Demand for service
7.3. Give details of how the results of the impact assessment will be published
This Equalities Impact Assessment will be available on the Wiltshire Council website and will also be listed as part of an agenda item for Wiltshire Money Service
Step 8 – action plan
| Actions | Target date | |
|---|---|---|
| Involvement, Consultation and Partnerships |
Discussions to be had with; CITIZENS ADVICE BUREAU Wiltshire Money Need to consult with equality groups as required |
November 2010 |
| Data collection and evidence |
As the Debt Recovery Policy will be a new policy data collection and evidence will be collected during the first 24 months of the policy. First review of policy and EIA to be carried out no later than 2012, however if a need arises before then this will be addressed. |
November 2012 |
| Assessment and analysis |
|
November 2011 November 2012 |
| Procurement and Commissioning | All 3rd parties involved are subject to their own funding and as such their longevity will need to be monitored to make sure the access to advice and support remains in place for our customers | Ongoing |
| Monitoring, evaluating and reviewing |
As stated previously this EIA and the policy itself will be subject to review no later than 24 months after the policy is adopted. It is also anticipated that the EIA may need to be review once further clarification of the Equality act 2010 that came into force in October. And the proposed new socio-economic duty |
Before November 2012 |
Sign-off
The policy has been fully assessed in relation to its potential effects on equality and all relevant concerns have been addressed.
Author of policy and EIA
Principal Accountant, Department of Resources - 2 November 2010
Director level sign off
Head of Finance, Department of Resources - 2 November 2010
Contact Details (LiveLink)
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Last updated: 18 April 2011
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