FOREWORD
Section 75 of the Northern Ireland Act 1998 (the Act) requires public authorities, in carrying out their functions relating to Northern Ireland, to have due regard to the need to promote equality of opportunity and regard to the desirability of promoting good relations across a range of categories outlined in the Act.
In our equality scheme we set out how The Commissioner for Survivors of Institutional Childhood Abuse proposes to fulfil the Section 75 statutory duties.
We will commit the necessary resources in terms of people, time and money to make sure that the Section 75 statutory duties are complied with and that the equality scheme is implemented effectively, and on time.
We commit to having effective internal arrangements in place for ensuring our effective compliance with the Section 75 statutory duties and for monitoring and reviewing our progress.
We will develop and deliver a programme of communication and training with the aim of ensuring that our staff are made fully aware of our equality scheme and understand the commitments and obligations within it.
The office of the Commissioner for Survivors of Institutional Childhood Abuse are fully committed to effectively fulfilling our Section 75 statutory duties across all our functions (including service provision, employment and procurement) through the effective implementation of our equality scheme.
We realise the important role that the community and voluntary sector and the general public have to play to ensure the Section 75 statutory duties are effectively implemented. Our equality scheme demonstrates how determined we are to ensure there are opportunities, for people affected by our work, to positively influence how we carry out our functions in line with our Section 75 statutory duties. It also offers the means whereby persons directly affected by what they consider to be a failure, on our part, to comply with our equality scheme, can make complaints.
On behalf of the office of the Commissioner for Survivors of Institutional Childhood Abuse staff will support and endorse this equality scheme which has been drawn up in accordance with Section 75 and Schedule 9 of the Northern Ireland Act 1998 and Equality Commission guidelines.
CHAPTER 1 INTRODUCTION
Section 75 of the Northern Ireland Act 1998
1.1 Section 75 of the Northern Ireland Act 1998 (the Act) requires the office of the Commissioner for Survivors of Institutional Childhood Abuse to comply with two statutory duties:
Section 75 (1)
In carrying out our functions relating to Northern Ireland we are required to have due regard to the need to promote equality of opportunity between:
• persons of different religious belief, political opinion, racial group, age, marital status or sexual orientation
• men and women generally
• persons with a disability and persons without
• persons with dependants and persons without
Section 75 (2)
In addition, without prejudice to the obligations above, in carrying out our functions in relation to Northern Ireland we are required to have regard to the desirability of promoting good relations between persons of different religious belief, political opinion or racial group.
“Functions” include the “powers and duties” of a public authority. This includes our employment and procurement functions. Please see below under “Who we are and what we do” for a detailed explanation of our functions.
How we propose to fulfil the Section 75 duties in relation to the relevant functions of the office of the Commissioner for Survivors of Institutional Childhood Abuse
1.2 Schedule 9 4. (1) of the Act requires the office of the Commissioner for Survivors of Institutional Childhood Abuse as a designated public authority to set out in an equality scheme how it proposes to fulfil the duties imposed by Section 75 in relation to its relevant functions. This equality scheme is intended to fulfil that statutory requirement. It is both a statement of our arrangements for fulfilling the Section 75 statutory duties and our plan for their implementation.
1.3 The office of the Commissioner for Survivors of Institutional Childhood Abuse is committed to the discharge of its Section 75 obligations in all parts of our organisation and we will commit the necessary available resources in terms of people, time and money to ensure that the Section 75 statutory duties are complied with and that our equality scheme can be implemented effectively.
WHO WE ARE AND WHAT WE DO
Powers and duties of the Commissioner for Survivors of Institutional Childhood Abuse
The Office of the Commissioner for Survivors of Institutional Childhood Abuse (COSICA) was established on 14 December 2020, in accordance with the recommendations outlined in the Historical Institutional Abuse Inquiry Report published in January 2017, and under the terms of the Historical Institutional Abuse (Northern Ireland) Act 2019 (HIA NI Act 2019). COSICA is a Non-Departmental Public Body of The Executive Office (TEO).
Under the HIA NI Act 2019 the principal aim of COSICA is to represent the interests of victims and survivors of institutional childhood abuse, defined as any person who suffered abuse while a child and while resident in an institution between 1922 and 1995.
COSICA’s additional statutory functions and duties in relation to victims and survivors of institutional childhood abuse include: advising on matters concerning the interests of victims and survivors; establishing an advisory panel of victims and survivors; encouraging the provision and coordination of services and where appropriate identifying gaps; monitoring specialist facilities for victims and survivors; monitoring and publicising the Historical Institutional Abuse Redress Board. In furtherance of these functions the HIA NI Act 2019 provides COSICA with a number of statutory powers:
• Powers to undertake or commission research into matters concerning the interests of victims and survivors;
• Powers to compile information concerning the interests of victims and survivors;
• Powers to provide advice or information on matters concerning the interests of victims and survivors;
• Powers to publish anything concerning the interests of victims and survivors;
• Powers to make representations or recommendations to any person concerning the interests of victims and survivors.
The Commissioner
The Commissioner is appointed for an initial five-year period, which may be extended subject to negotiation with the appointee. Fiona Ryan was appointed to the role of Commissioner for Survivors of Institutional Childhood Abuse by then First Minister Arlene Foster and Deputy First Minister Michelle O’Neill and took up the post on 14 December 2020.
COSICA is a Corporation Sole and the Commissioner fulfils the role of the Board to COSICA.
On 20 January 2017, the Report of the Historical Institutional Abuse Inquiry was published outlining the key findings and recommendations of the Inquiry. The Inquiry found systemic failings by institutions as well as by the state in their duties towards those children in their care between the years of 1922-1995. One of the recommendations contained in the report was the appointment of a statutory Commissioner for Survivors of Institutional Childhood Abuse.
COSICA was established under the auspices of the HIA NI Act 2019, which received Royal Assent on 5 November 2019. COSICA exists primarily to fulfil the organisation’s statutory duties, acting as the primary advocate for victims and survivors of historical institutional childhood abuse within the wider strategic context of the implementation of the Inquiry’s recommendations.
The implementation of these recommendations falls under the draft Programme for Government Framework 2016-2021 Outcome 8: “We care for others and we help those in need”.
It also aligns with the objective 2.11 in the TEO Business Plan 1/20 which states that the Department will “Continue with HIA implementation work to establish the structures necessary to pay compensation and advocacy and support for victims and survivors”.
Mission
COSICA’s role is to represent the interests of victims and survivors of historical institutional childhood abuse in accordance with the HIA NI Act 2019. The Commissioner will work to empower victims and survivors to exercise their rights.
Values
All of COSICA’s work, both our longer-term strategic focus and day to day operations are informed by our key values; that we are:
Victim and Survivor Focused
Having a systemic and operational focus on the needs, interests and concerns of victims and survivors, ensuring we engage with survivors in a compassionate, sensitive and trauma-informed manner, and that these needs, interests and concerns inform ongoing work.
Rights Based
Encouraging and supporting victims and survivors to exercise and fulfil their rights and encourage organisations and service providers to meet their obligations in respect of these rights.
Trauma-Aware
The Office of the Commissioner works to ensure that staff are aware of the impact of trauma and sensitive in their engagement with victims and survivors. While the office does not provide health and social care services (we provide victims and survivors with information on available services and signpost accordingly) we work at all times to be responsive to the needs and concerns being expressed by victims and survivors.
Purpose, Aims and Activities
Our work will be undertaken in accordance with the following six themes:
• Developing the Office of the Commissioner
• Advocacy and Engagement
• Policy and Research
• Monitoring
• Encouraging provision of services
• Partnering to deliver on HIA relevant initiatives
In order to achieve the outcomes, we will continue to build our organisational capacity to enable us to fulfil our statutory duties; and exercise our statutory powers, in a manner that reflects the interests and concerns of victims and survivors, and in parallel enables us to fulfil our corporate governance and accountability obligations.
CHAPTER 2 OUR ARRANGEMENTS FOR ASSESSING OUR COMPLIANCE WITH THE SECTION 75 DUTIES (Schedule 9 4. (2) (a))
2.1 Some of our arrangements for assessing our compliance with the Section 75 statutory duties are outlined in other relevant parts of this equality scheme.
In addition we have the following arrangements in place for assessing our compliance:
Responsibilities and reporting
2.2 We are committed to the fulfilment of our Section 75 obligations in all parts of our work.
2.3 Responsibility for the effective implementation of our equality scheme lies with the Head of Corporate Services. The Head of Corporate Services is accountable to the Commissioner for the development, implementation, maintenance and review of the equality scheme in accordance with Section 75 and Schedule 9 of the Northern Ireland Act 1998, including any good practice or guidance that has been or may be issued by the Equality Commission.
2.4 If you have any questions or comments regarding our equality scheme, please contact in the first instance Joanne McComb at the address given below and we will respond to you as soon as possible:
5th Floor South
Queen’s Court
56-66 Upper Queen Street
Belfast
BT1 6FD
Telephone 028 9054 4985
Email: info@cosica-ni.org
2.5 Objectives and targets relating to the statutory duties will be integrated into our strategic and operational business plans.
2.6 Employees’ job descriptions and performance plans reflect their contributions to the discharge of the Section 75 statutory duties and implementation of the equality scheme, where relevant. The personal performance plans are subject to appraisal in the annual performance review.
2.7 The office of the Commissioner for Survivors of Institutional Childhood Abuse will prepare an annual report on the progress we have made on implementing the arrangements set out in this equality scheme to discharge our Section 75 statutory duties (Section 75 annual progress report).
The Section 75 annual progress report will be sent to the Equality Commission by 31 August each year and will follow any guidance on annual reporting issued by the Equality Commission.
Progress on the delivery of Section 75 statutory duties will also be included in our (organisational) annual report.
2.8 The latest Section 75 annual progress report will be available on our website https://www.cosica-ni.org or by contacting:
5th Floor South
Queen’s Court
56-66 Upper Queen Street
Belfast
BT1 6FD
Telephone 028 9054 4985
Email: info@cosica-ni.org
2.9 The office of the Commissioner will liaise closely with the Equality Commission to ensure that progress on the implementation of our equality scheme is maintained.
Action plan/action measures
2.11 The office of the Commissioner will develop an action plan to promote equality of opportunity and good relations.
2.12 The action measures that will make up our action plan will be relevant to our functions. They will be developed and prioritised on the basis of an audit of inequalities. The audit of inequalities will gather and analyse information across the Section 75 categories4 to identify the inequalities that exist for our service users and those affected by our policies.
2.13 Action measures will be specific, measurable, linked to achievable outcomes, realistic and time bound. Action measures will include performance indicators and timescales for their achievement.
2.14 We will develop any action plans for a period of between one and five years in order to align them with our corporate and business planning cycles. Implementation of the action measures will be incorporated into our business planning process.
2.15 We will seek input from our stakeholders and consult on our action plan before we send it to the Equality Commission and thereafter when reviewing the plan as per 2.16 below.
2.16 We will monitor our progress on the delivery of our action measures annually and update the action plan as necessary to ensure that it remains effective and relevant to our functions and work.
2.17 The office of the Commissioner will inform the Commission of any changes or amendments to our action plan and will also include this information in our Section 75 annual progress report to the Commission. Our Section 75 annual progress report will incorporate information on progress we have made in implementing our action plans/action measures.
2.18 Once finalised, our action plan will be available on our website:
https://www.cosica-ni.org
If you require it in an alternative format, please contact us on the details provided.
CHAPTER 3 - OUR ARRANGEMENTS FOR CONSULTING
(Schedule 9 4. (2) (a)) - on matters to which a duty (S75 (1) or (2)) is likely to be relevant (including details of the persons to be consulted).
(Schedule 9 4. (2) (b)) on the likely impact of policies adopted or proposed to be adopted by us on the promotion of equality of opportunity.
3.1 We recognise the importance of consultation in all aspects of the implementation of our statutory equality duties. We will consult on our equality scheme, action measures, equality impact assessments and other matters relevant to the Section 75 statutory duties.
3.2 We are committed to carrying out consultation in accordance with the following principles (as contained in the Equality Commission’s guidance ‘Section 75 of the Northern Ireland Act 1998 – A Guide for Public Authorities (April 2010)’):
3.2.1 All consultations will seek the views of those directly affected by the matter/policy, the Equality Commission, representative groups of Section 75 categories, other public authorities, voluntary and community groups, our staff and their trades unions and such other groups who have a legitimate interest in the matter, whether or not they have a direct economic or personal interest.
Initially all consultees (see Appendix 3), as a matter of course, will be notified (by email or post) of the matter/policy being consulted upon to ensure they are aware of all consultations. Thereafter, to ensure the most effective use of our and our consultees ‘resources, we will take a targeted approach to consultation for those consultees that may have a particular interest in the matter/policy being consulted upon and to whom the matter/policy is of particular relevance. This may include for example regional or local consultations, sectoral or thematic consultation etc.
3.2.2 Consultation with all stakeholders will begin as early as possible. We will engage with affected individuals and representative groups to identify how best to consult or engage with them. We will ask our consultees what their preferred consultation methods are and will give consideration to these. Methods of consultation could include:
• Face-to-face meetings;
• Focus groups;
• Written documents with the opportunity to comment in writing;
• Questionnaires;
• Information/notification by email with an opportunity to opt in/opt out of the consultation;
• Internet discussions; or
• Telephone consultations.
This list is not exhaustive, and we may develop other additional methods of consultation more appropriate to key stakeholders and the matter being consulted upon.
3.2.3 We will consider the accessibility and format of every method of consultation we use in order to remove barriers to the consultation process. Specific consideration will be given as to how best to communicate with children and young people, people with disabilities (in particular people with learning disabilities) and minority ethnic communities. We take account of existing and developing good practice, including the Equality Commission’s guidance Let’s Talk Let’s Listen – Guidance for public authorities on consulting and involving children and young people (2008).
We will conduct base level research and ensure that all of our potential target audience is being reached effectively. These measures (post research) may include or extend to website availability in alternative languages, options for alternative fonts or colours of print on publications.
Information will be made available, on request, in alternative formats8, in a timely manner, usually within 3-5 working days. We will ensure that such consultees have equal time to respond.
3.2.4 Specific training will be provided to those facilitating consultations to ensure that they have the necessary skills to communicate effectively with consultees.
3.2.5 To ensure effective consultation with consultees6 on Section 75 matters, we will develop a programme of awareness raising on the Section 75 statutory duties and the commitments in our equality scheme by undertaking the following:
COSICA will consult with consultees via the following methods: • Provision of information sessions;
• Meetings between COSICA staff and Audit and Risk Assurance Committee;
• Staff training on issues relating to equality;
• Availability of equality scheme and related documents on COSICA website.
We will be circulating our equality scheme to all consultees. Our consultees list will be highly diverse and will draw upon people from all backgrounds, ages, genders, disabilities, religions, ethnicities and sexual orientations. Our consultation list can be found at Appendix 3.
Our information raising arrangements will be initiated by circulating our audit of inequalities, our accompanying action plan and this equality scheme to our consultees.
3.2.6 The consultation period lasts for a minimum of twelve weeks to allow adequate time for groups to consult amongst themselves as part of the process of forming a view. However, in exceptional circumstances when this timescale is not feasible (for example implementing EU Directives or UK wide legislation, meeting Health and Safety requirements, addressing urgent public health matters or complying with Court judgements), we may shorten timescales to eight weeks or less before the policy is implemented. We may continue consultation thereafter and will review the policy as part of our monitoring commitments.
Where, under these exceptional circumstances, we must implement a policy immediately, as it is beyond our authority’s control, we may consult after implementation of the policy, in order to ensure that any impacts of the policy are considered.
3.2.7 If a consultation exercise is to take place over a period when consultees are less able to respond, for example, over the summer or Christmas break, or if the policy under consideration is particularly complex, we will give consideration to the feasibility of allowing a longer period for the consultation.
3.2.8 We are conscious of the fact that affected individuals and representative groups may have different needs. We will take appropriate measures to ensure full participation in any meetings that are held. We will consider for example the time of day, the appropriateness of the venue, in particular whether it can be accessed by those with disabilities, how the meeting is to be conducted, the use of appropriate language, whether a signer and/or interpreter is necessary, and whether the provision of childcare and support for other carers is required.
3.2.9 We make all relevant information available to consultees in appropriate formats to ensure meaningful consultation. This includes detailed information on the policy proposal being consulted upon and any relevant quantitative and qualitative data.
3.2.10 In making any decision with respect to a policy adopted or proposed to be adopted, we take into account any assessment and consultation carried out in relation to the policy.
3.2.11 We provide feedback to consultees in a timely manner. A feedback report is prepared which includes summary information on the policy consulted upon, a summary of consultees’ comments and a summary of our consideration of and response to consultees’ input. The feedback is provided in formats suitable to consultees. (Please see also 6.3)
3.3 A list of our consultees is included in this equality scheme at Appendix 3. It can also be obtained from our website at:
or by contacting
5th Floor South
Queen’s Court
56-66 Upper Queen Street
Belfast
BT1 6FD
Telephone 028 9054 4985
3.4 Our consultation list is not exhaustive and is reviewed on an annual basis to ensure it remains relevant to our functions and policies.
We welcome enquiries from any person/s or organisations wishing to be added to the list of consultees. Please contact admin@cosica-ni.org to provide your contact details and have your areas of interest noted or have your name/details removed or amended. Please also inform us at this stage if you would like information sent to you in a particular format or language.
CHAPTER 4 OUR ARRANGEMENTS FOR ASSESSING, MONITORING AND PUBLISHING THE IMPACT OF POLICIES (SCHEDULE 9 4. (2) (B); SCHEDULE 9 4. (2) (C); SCHEDULE 9 4. (2) (D); SCHEDULE 9 9. (1); SCHEDULE 9 9. (2)) OUR ARRANGEMENTS FOR ASSESSING THE LIKELY IMPACT OF POLICIES ADOPTED OR PROPOSED TO BE ADOPTED ON THE PROMOTION OF EQUALITY OF OPPORTUNITY (SCHEDULE 9 4. (2) (B))
4.1 In the context of Section 75, ‘policy’ is very broadly defined and it covers all the ways in which we carry out or propose to carry out our functions in relation to Northern Ireland. In respect of this equality scheme, the term policy is used for any (proposed/amended/existing) strategy, policy initiative or practice and/or decision, whether written or unwritten and irrespective of the label given to it, eg, ‘draft,’ ‘pilot,’ ‘high level’ or ‘sectoral’.
4.2 In making any decision with respect to a policy adopted or proposed to be adopted, we take into account any assessment and consultation carried out in relation to the policy, as required by Schedule 9 9. (2) of the Northern Ireland Act 1998.
4.3 The office of the Commissioner uses the tools of screening and equality impact assessment to assess the likely impact of a policy on the promotion of equality of opportunity and good relations. In carrying out these assessments we will relate them to the intended outcomes of the policy in question and will also follow Equality Commission guidance:
• the guidance on screening, including the screening template, as detailed in the Commission’s guidance ‘Section 75 of the Northern Ireland Act 1998 – A Guide for Public Authorities (April 2010)’; and
• on undertaking an equality impact assessment as detailed in the Commission’s guidance ‘Practical guidance on equality impact assessment (February 2005)’.
Screening 4.4 The purpose of screening is to identify those policies that are likely to have an impact on equality of opportunity and/or good relations.
4.5 Screening is completed at the earliest opportunity in the policy development/review process. Policies which we propose to adopt will be subject to screening prior to implementation. For more detailed strategies or policies that are to be put in place through a series of stages, we will screen at various stages during implementation.
4.6 The lead role in the screening of a policy is taken by the policy decision maker who has the authority to make changes to that policy. However, screening will also involve other relevant team members, for example, equality specialists, those who implement the policy and staff members from other relevant work areas. Where possible we will include key stakeholders in the screening process.
4.7 The following questions are applied to all our policies as part of the screening process:
• What is the likely impact on equality of opportunity for those affected by this policy, for each of the Section 75 equality categories? (minor/major/none)
• Are there opportunities to better promote equality of opportunity for people within the Section 75 equality categories?
• To what extent is the policy likely to impact on good relations between people of a different religious belief, political opinion or racial group? (minor/major/none)
• Are there opportunities to better promote good relations between people of a different religious belief, political opinion or racial group?
4.8 In order to answer the screening questions, we gather all relevant information and data, both qualitative and quantitative. In taking this evidence into account we consider the different needs, experiences and priorities for each of the Section 75 equality categories. Any screening decision will be informed by this evidence.
4.9 Completion of screening, taking into account our consideration of the answers to all four screening questions set out in 4.7 above, will lead to one of the following three outcomes: 1. The policy has been ‘screened in’ for equality impact assessment; 2. The policy has been ‘screened out’ with mitigation or an alternative policy proposed to be adopted; 3. The policy has been ‘screened out’ without mitigation or an alternative policy proposed to be adopted.
4.10 If our screening concludes that the likely impact of a policy is ‘minor’ in respect of one, or more, of the equality of opportunity and/or good relations categories, we may on occasion decide to proceed with an equality impact assessment, depending on the policy.
If an EQIA is not to be conducted, we will nonetheless consider measures that might mitigate the policy impact as well as alternative policies that might better achieve the promotion of equality of opportunity and/or good relations.
Where we mitigate, we will outline in our screening template the reasons to support this decision together with the proposed changes, amendments or alternative policy.
This screening decision will be ‘signed off’ by the appropriate policy lead within the office of the Commissioner.
4.11 If our screening concludes that the likely impact of a policy is ‘major’ in respect of one, or more, of the equality of opportunity and/or good relations categories, we will normally subject the policy to an equality impact assessment. This screening decision will be ‘signed off’ by the appropriate policy lead within office of the Commissioner.
4.12 If our screening concludes that the likely impact of a policy is ‘none’, in respect of all of the equality of opportunity and/or good relations categories, we may decide to screen the policy out. If a policy is ‘screened out’ as having no relevance to equality of opportunity or good relations, we will give details of the reasons for the decision taken. This screening decision will be ‘signed off’ by the appropriate policy lead within the office of the Commissioner.
4.13 As soon as possible following the completion of the screening process, the screening template, signed off and approved by the senior manager responsible for the policy, will be made available on our website:
and on request.
Telephone: 028 9054 4985
Email: admin@cosica-ni.org
4.14 If a consultee, including the Equality Commission, raises a concern about a screening decision based on supporting evidence, we will review the screening decision.
4.15 Our screening reports are published quarterly [see below at 4.20 - 4.22 and 4.23 for details].
Equality impact assessment
4.16 An equality impact assessment (EQIA) is a thorough and systematic analysis of a policy, whether that policy is formal or informal, and irrespective of the scope of that policy. The primary function of an EQIA is to determine the extent of any impact of a policy upon the Section 75 categories and to determine if the impact is an adverse one. It is also an opportunity to demonstrate the likely positive outcomes of a policy and to seek ways to more effectively promote equality of opportunity and good relations.
4.17 Once a policy is screened and screening has identified that an equality impact assessment is necessary, we will carry out the EQIA in accordance with Equality Commission guidance. The equality impact assessment will be carried out as part of the policy development process, before the policy is implemented.
4.18 Any equality impact assessment will be subject to consultation at the appropriate stage(s). (For details see above Chapter 3 “Our Arrangements for Consulting”).
Our arrangements for publishing the results of the assessments of the likely impact of policies we have adopted or propose to adopt on the promotion of equality of opportunity (Schedule 9 4. (2) (d); Schedule 9 9. (1))
4.19 We make publicly available the results of our assessments (screening and EQIA) of the likely impact of our policies on the promotion of equality of opportunity and good relations.
What we publish
4.20 Screening reports
These are published quarterly. Screening reports detail:
• All policies screened by COSICA over the three-month period.
• A statement of the aim(s) of the policy/policies to which the assessment relates.
• Consideration given to measures which might mitigate any adverse impact.
• Consideration given to alternative policies which might better achieve the promotion of equality of opportunity;
• Screening decisions, ie:
➢ whether the policy has been ‘screened in’ for equality impact assessment.
➢ whether the policy has been ‘screened out’ with mitigation or an alternative policy proposed to be adopted.
➢ whether the policy has been ‘screened out’ without mitigation or an alternative policy proposed to be adopted.
• Where applicable, a timetable for conducting equality impact assessments.
• A link to the completed screening template(s) on our website
4.21 Screening templates For details on the availability of our screening templates please refer to 4.13.
4.22 Equality impact assessments
EQIA reports are published once the impact assessment has been completed. These reports include:
• A statement of the aim of the policy assessed;
• Information and data collected;
• Details of the assessment of impact(s);
• Consideration given to measures which might mitigate any adverse impact;
• Consideration given to alternative policies which might better achieve the promotion of equality of opportunity;
• Consultation responses;
• The decision taken;
• Future monitoring plans.
How we publish the information
4.23 All information we publish is accessible and can be made available in alternative formats on request. Please see 6.3 below.
Where we publish the information
4.24 The results of our assessments (screening reports and completed templates, the results of equality impact assessments) are available on our website
and by contacting:
5th Floor South
Queen’s Court 56-66
Upper Queen Street
Belfast
BT1 6FD
Telephone 028 9054 4985
Email: info@cosica-ni.org
4.25 In addition to the above, screening reports (electronic link or hard copy on request if more suitable for recipients) which include all policies screened over a 3 month period are also sent directly to all consultees on a quarterly basis.
4.26 We will inform the general public about the availability of this material through communications such as press releases where appropriate.
Our arrangements for monitoring any adverse impact of policies we have adopted on equality of opportunity (Schedule 9 4. (2) (c))
4.27 Monitoring can assist us to deliver better public services and continuous improvements. Monitoring Section 75 information involves the processing of sensitive personal data (data relating to the racial or ethnic origin of individuals, sexual orientation, political opinion, religious belief, etc). In order to carry out monitoring in a confidential and effective manner, the office of the Commissioner follows guidance from the Office of the Information Commissioner and the Equality Commission.
4.28 We monitor any adverse impact on the promotion of equality of opportunity of policies we have adopted. We are also committed to monitoring more broadly to identify opportunities to better promote equality of opportunity and good relations in line with Equality Commission guidance.
4.29 The systems we have established to monitor the impact of policies and identify opportunities to better promote equality of opportunity and good relations are:
• The collection, collation, and analysis of existing relevant primary quantitative and qualitative data across all nine equality categories on an ongoing basis;
• The collection, collation, and analysis of existing relevant secondary sources of quantitative and qualitative data across all nine equality categories on an ongoing basis;
• An audit of existing information systems within one year of approval of this equality scheme, to identify the extent of current monitoring and take action to address any gaps in order to have the necessary information on which to base decisions;
• Undertaking or commissioning new data if necessary.
4.30 If over a two year period monitoring and evaluation show that a policy results in greater adverse impact than predicted, or if opportunities arise which would allow for greater equality of opportunity to be promoted, we will ensure that the policy is revised to achieve better outcomes for relevant equality groups.
4.31 We will review our EQIA monitoring information on an annual basis.
We review our EQIA monitoring information on an annual basis. Other monitoring information is reviewed on an annual basis; this includes Equality of Opportunity Policies, Human Resource policies and any procedures which may impact upon Section 75.
For the purposes of Section 75 monitoring COSICA will utilise the following as a means of data collection going forward:
• Section 75 monitoring at COSICA engagements;
• Section 75 monitoring of COSICA investigations.
Our arrangements for publishing the results of our monitoring (Schedule 9 4. (2) (d))
4.32 Schedule 9 4. (2) (d) requires us to publish the results of the monitoring of adverse impacts of policies we have adopted. However, we are committed to monitoring more broadly and the results of our policy monitoring are published as follows:
4.33 EQIA monitoring information is published as part of our Section 75 annual progress report [see 2.7]
4.34 Results of equality monitoring will be published and provided for consultees on the COSICA website and will also be available on request by emailing admin@cosica.org
4.35 All information published is accessible and can be made available in alternative formats on request. Please see below at 6.3 for details.
CHAPTER 5 STAFF TRAINING (Schedule 9 4.(2) (e))
Commitment to staff training
5.1 We recognise that awareness raising and training play a crucial role in the effective implementation of our Section 75 duties.
5.2 The office wishes to positively communicate the commitment of the Commissioner for Survivors of Institutional Childhood Abuse to the Section 75 statutory duties, both internally and externally.
To this end we will introduce an effective communication and training programme for all staff and will ensure that our commitment to the Section 75 statutory duties is made clear in all relevant publications.
Training objectives
5.3 The Commissioner for Survivors of Institutional Childhood Abuse will draw up a detailed training plan for its staff which will aim to achieve the following objectives:
• to raise awareness of the provisions of Section 75 of the Northern Ireland Act 1998, our equality scheme commitments and the particular issues likely to affect people across the range of Section 75 categories, to ensure that our staff fully understand their role in implementing the scheme;
• to provide those staff involved in the assessment of policies (screening and EQIA) with the necessary skills and knowledge to do this work effectively;
• to provide those staff who deal with complaints in relation to compliance with our equality scheme with the necessary skills and knowledge to investigate and monitor complaints effectively;
• to provide those staff involved in consultation processes with the necessary skills and knowledge to do this work effectively;
• to provide those staff involved in the implementation and monitoring of the effective implementation of the Commissioner for Survivors of Institutional Childhood Abuse equality scheme with the necessary skills and knowledge to do this work effectively.
Awareness raising and training arrangements
5.4 The following arrangements are in place to ensure all our staff, Chief Commissioner and the Audit and Risk Assurance Committee [ARAC] are aware of and understand our equality obligations.
• We will develop a summary of this equality scheme and make it available to all staff.
• We will provide access to copies of the full equality scheme for all staff; ensure that any queries or questions of clarification from staff are addressed effectively.
• Staff within the Commissioner for Older People for Northern Ireland will receive a briefing on this equality scheme within 14 days of the approval of the scheme.
• The Section 75 statutory duties form part of induction training for new staff.
• Focused training is provided for key staff within COSICA who are directly engaged in taking forward the implementation of our equality scheme commitments (for example those involved in research and data collection, policy development, service design, conducting equality impact assessments, consultation, monitoring and evaluation).
• Where appropriate, training will be provided to ensure staff are aware of the issues experienced by the range of Section 75 groups.
• When appropriate and on an ongoing basis, arrangements will be made to ensure staff are kept up to date with Section 75 developments.
• COSICA operate under a Commissioner as opposed to a board, however, ARAC (Audit and Risk Assurance Committee) are sought for approval on a wide range of issues relative to business needs.
5.5 Training and awareness raising programmes will, where relevant, be developed in association with the appropriate Section 75 groups and our staff. All training will be recorded, monitored and updated to meet the needs of the organisation.
In order to share resources and expertise, the Commissioner for Survivors of Institutional Childhood Abuse will, where possible, work closely with other bodies and agencies in the development and delivery of training.
Monitoring and evaluation
5.6 Our training programme is subject to the following monitoring and evaluation arrangements:
• We evaluate the extent to which all participants in this training programme have acquired the necessary skills and knowledge to achieve each of the above objectives.
• The extent to which training objectives have been met will be reported on as part of the Section 75 annual progress report, which will be sent to the Equality Commission.
CHAPTER 6 OUR ARRANGEMENTS FOR ENSURING AND ASSESSING PUBLIC ACCESS TO INFORMATION AND SERVICES WE PROVIDE (Schedule 9 4. (2) (F))
6.1 COSICA is committed to ensuring that the information we disseminate and the services we provide are fully accessible to all parts of the community in Northern Ireland. We keep our arrangements under review to ensure that this remains the case.
6.2 We are aware that some groups will not have the same access to information as others. In particular:
• People with sensory, learning, communication and mobility disabilities may require printed information in other formats.
• Members of ethnic minority groups, whose first language is not English, may have difficulties with information provided only in English.
• Children and young people may not be able to fully access or understand information. Access to information
6.3 To ensure equality of opportunity in accessing information, we provide information in alternative formats on request, where reasonably practicable. Where the exact request cannot be met we will ensure a reasonable alternative is provided.
Alternative formats may include Easy Read, Braille, audio formats (CD, mp3 or DAISY), large print or minority languages to meet the needs of those for whom English is not their first language.
We will respond to requests for information in alternative formats in a timely manner, usually within one month.
COSICA will seek to communicate Equality through;
• Increasing access and participation for victims and survivors of institutional childhood abuse in Northern Ireland and Identifying areas of research which aim to cater within 75 identities.
• The development and implementation of the COSICA Disability Action Plan.
6.4 In disseminating information through the media we will seek to advertise in the press where appropriate.
6.5 COSICA will ensure public access to the Equality Scheme through placing the scheme on the COSICA website both through the consultation phase and post approval phase.
All information relevant to our equality commitments will be available on our website
or on request by writing to:
The Commissioner for Survivors of Institutional Childhood Abuse
5th Floor Queen’s Court
Upper Queen Street
Belfast
BT1 6FD
Or email
Access to services
6.6 The Commissioner for Survivors of Institutional Childhood Abuse is committed to ensuring that all of our services are fully accessible to everyone in the community across the Section 75 categories.
The Commissioner for Survivors of Institutional Childhood Abuse also adheres to the relevant provisions of current anti-discrimination legislation.
6.7 Arrangements for ensuring public access to COSICA services:
• COSICA offices are placed in a building with full disabled access on all floors;
• COSICA has developed a fully functioning website which clearly outlines the services provided;
• COSICA have been engaging with victims and survivors throughout Northern Ireland, encouraging access to services;
• Promoting public access to information and services.
6.8 We monitor across all our functions in relation to access to information and services, to ensure equality of opportunity and good relations are prompted.
6.9 COSICA monitors elements of section 75 activity through:
• Equal Opportunities forms within recruitment;
• Logging details of any investigations/casework undertaken;
• Monitoring attendances at COSICA engagements;
• Logging details of any complaints received.
CHAPTER 7 TIMETABLE FOR MEASURES WE PROPOSE IN THIS EQUALITY SCHEME (Schedule 9 4. (3) (b))
7.1 Appendix 4 outlines our timetable for all measures proposed within this equality scheme. The measures outlined in this timetable will be incorporated into our business planning processes.
7.2 This timetable is different from and in addition to our commitment to developing action plans/action measures to specifically address inequalities and further promote equality of opportunity and good relations. We have included in our equality scheme a commitment to develop an action plan. Accordingly, this commitment it is listed in the timetable of measures at Appendix 4. For information on these action measures please see above at 2.11 – 2.18.
CHAPTER 8 OUR COMPLAINTS PROCEDURE (Schedule 9 10.)
8.1 COSICA are responsive to the views of members of the public. We will endeavour to resolve all complaints made to us.
8.2 Schedule 9 paragraph 10 of the Act refers to complaints. A person can make a complaint to a public authority if the complainant believes he or she may have been directly affected by an alleged failure of the authority to comply with its approved equality scheme.
If the complaint has not been resolved within a reasonable timescale, the complaint can be brought to the Equality Commission.
8.3 A person wishing to make a complaint that COSICA has failed to comply with its approved equality scheme should contact:
5th Floor South
Queen’s Court
56-66 Upper Queen Street
Belfast
BT1 6FD
Telephone: 028 9054 4985
Email: info@cosica-ni.org
8.4 We will in the first instance acknowledge receipt of each complaint within 10 working days.
8.5 COSICA will carry out an internal investigation of the complaint and will respond substantively to the complainant within one (1) month of the date of receiving the letter of complaint. Under certain circumstances, if the complexity of the matter requires a longer period, the period for response to the complainant may be extended to two (2) months. In those circumstances, the complainant will be advised of the extended period within one month of making the complaint.
8.6 During this process the complainant will be kept fully informed of the progress of the investigation into the complaint and of any outcomes.
8.7 In any subsequent investigation by the Equality Commission, COSICA will co-operate fully, providing access in a timely manner to any relevant documentation that the Equality Commission may require.
Similarly, COSICA will co-operate fully with any investigation by the Equality Commission under sub-paragraph 11 (1) (b) of Schedule 9 to the Northern Ireland Act 1998.
8.8 COSICA will make all efforts to implement promptly and in full any recommendations arising out of any Commission investigation.
CHAPTER 9 PUBLICATION OF OUR EQUALITY SCHEME (Schedule 9 4. (3) (c))
9.1 COSICA’s equality scheme is available free of charge in print form and alternative formats from:
5th Floor South
Queen’s Court
56-66 Upper Queen Street
Belfast
BT1 6FD
Telephone: 028 9054 4985
Email: info@cosica-ni.org
9.2 Our equality scheme is also available on our website at: https://www.cosica-ni.org
9.3 The following arrangements are in place for the publication in a timely manner of our equality scheme to ensure equality of access:
• We will make every effort to communicate widely the existence and content of our equality scheme. This may include press releases, prominent advertisements in the press, the internet and direct mail shots to groups representing the various categories in Section 75.
• We will email a link to our approved equality scheme to our consultees on our consultation lists. Other consultees without e-mail will be notified by letter that the scheme is available on request. We will respond to requests for the equality scheme in alternative formats in a timely manner, usually within 10 working days.
• Our equality scheme is available on request in alternative formats such as Easy Read, Braille, large print, audio formats (CD, mp3, DAISY) and in minority languages to meet the needs of those not fluent in English.
9.4 For a list of our stakeholders and consultees please see Appendix 3 of the equality scheme, visit our website at https://www.cosica-ni.org or contact
Telephone: 028 9054 4985
Email: info@cosica-ni.or
Chapter 10 Review of our equality scheme (Schedule 9 8. (3))
10.1 As required by Schedule 9 paragraph 8 (3) of the Northern Ireland Act 1998 we will conduct a thorough review of this equality scheme. This review will take place either within five years of submission of this equality scheme to the Equality Commission or within a shorter timescale to allow alignment with the review of other planning cycles.
The review will evaluate the effectiveness of our scheme in relation to the implementation of the Section 75 statutory duties relevant to our functions in Northern Ireland.
10.2 In undertaking this review we will follow any guidance issued by the Equality Commission. A report of this review will be made public on our website https://www.cosica-ni.org and sent to the Equality Commission.
Appendix items are available in the attached PDF. These items are:
- Organisational Chart
- Example groups relevant to the Section 75 categories for Northern Ireland purposes
- List of consultees
- Timetable for measures proposed
- Glossary of terms