EQUALITY MONITORING POLICY & GUIDANCE
July 2010
Document Ref No.Title of document / Equality Monitoring Policy & Guide
Author’s name / Collette Upton
Author’s job title / Equality & Diversity Manager
Dept / Service / Corporate Services
Doc. Status / Final Draft 1
Based on
Signed off by / Equality & Diversity Steering Group
Original Publication Date
Last Reviewed / New
Next review date / (2012)
Distribution / Trust wide / Internet
Has an Equality & Diversity Impact Assessment been completed? / YES
Consultation History
Version
/Date
/Consultation
v0.1
/June – July 2010
/Consultation with ETAGs
v.final1
/July 2010
/Approved by Equality Diversity Steering Group
V.final1
/July 22010
/Document control group
NHS Bolton is the name used to refer to Bolton Primary Care Trust. The legal identity of the organisation remains unchanged.
INTRODUCTION
NHS Bolton is committed to equality of opportunity in service delivery, employment, in its role as a community leader and as a procurer of services. We believe that all people have the right to be treated with dignity and respect and are committed to eliminating unfair and unlawful discrimination in all our policies, procedures and practices.
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Delivering needs led and patient centred services is the vision of a modern and responsive NHS and equality & diversity is at the heart of this. Our communities and service users are varied and diverse and understanding and responding to these diverse needs is essential to ensuring we effectively target resources so all sections of the community benefit equally from health care services.
Sometimes, without knowing, our services may not be designed in a way that maximises inclusion, and some groups of people are less likely to access particular services for a range of reasons. Furthermore, some groups of people may have a greater need for particular services or different requirements which we need to respond to.
Establishing equality monitoring is an essential step in gathering a range of data including:
· How services are taken up
· Gaps in service take-up
· Variations in satisfaction
· Detailed public health data
· Lifestyle information
This document has been produced by the Equality and Diversity Manager & Equality & Diversity Steering Group, to help staff develop their understanding of equality monitoring and its benefits, to establish a common standard and to guide staff though the process of equality monitoring.
WHY DO WE NEED TO EQUALITY MONITOR?
· Legislative requirements. Under various legislation we have a legal duty to ensure that we are not directly or indirectly discriminating against particular groups of people. In addition, we also have a duty to take account of race, gender and disability issues when planning or delivering services. Equality monitoring is an essential part of achieving this.
· Audit & Inspection. Principles such as eliminating discrimination, fair accesses to services, responding to diverse needs are central to Standards for Better Health and World Class Commissioning. Effective equality monitoring is essential to the achievement of these.
· To ensure optimum service delivery. Unless the PCT knows who its customers are, who is and who is not using services and what people think of them, the PCT cannot know if everyone who needs services are able to accesses them effectively. Equality monitoring allows us to look at this data for more detailed trends.
· To aid service planning. Monitoring is vital for planning and targeting service provision as it highlights gaps in services and can indicate new opportunities for improvements and developments.
· To improve the commissioning of services. By collecting data of patients at all stages of the NHS care we are better able to understand the health needs of different groups and build these needs into the way we commission services and target pubic health messages.
WHAT SHOULD WE MONITOR?
You should always be fully aware of what you want to achieve from a monitoring system before it is established in order to ensure the right data can be collected.
It is a pointless process to collect data if it will not be used and can also damage patient confidence.
This does not mean however that we should not collect this data, it just means that we should always use it as part of service improvement.
Age:
Generally, asking for actual age or DOB is better than categorising ages, as this allows you to be get more out of your data. Data from the Office of National Statistics is also collected in this way, therefore allowing you to group together ages in terms of what is most useful. However, Appendix 1 does include a suggested template which is in line with the Office of National Statistics suggested age bands.
Disability:
When monitoring Disability you should always use the definition of disability taken from the Disability Discrimination Act 1995 and ask people if, based on this, they consider themselves to have a disability (see Appendix 1). You should then ask people who consider themselves to have a disability to indicate the type of impairment that they have.
It is essential that information gathered about someone’s impairment is used only in relation to identify barriers to services or employment. They should not be used as a means of understanding a person’s needs, for instance translation, sign language, which are likely to be based on assumptions if using this data. If you wish to know this information you should add an additional question asking them to highlight any requirements they may have.
Ethnicity:
Information collected on ethnicity must, as a minimum, be consistent with Census classifications. The PCT’s template is now reflective of the forthcoming 2011 Census, which will ensure that our data is future-proof.
You may also want to consider asking individuals their Nationality if this data would be of use. However this should be included under a separate category and not included under ethnicity. Please see Appendix 1.
Gender:
We have come a long way in terms of gender equality and we now live in a society were people assume there is equality between men and women. But if we look more closely this is not the case:
Monitoring Gender Identity:
Monitoring of Gender Identity is a very sensitive area and should not be asked as standard. In some services, data on Gender Identity may be very useful, but careful consideration should be given when considering this, particularly when data is not anonymous.
Press for Change, the main UK organisation lobbying on behalf of trans people, suggest the following question, where you have a clear purpose for including it. A ‘trans gender’ option, alongside male and female, should never be used as this suggests there is a third gender.
Sexual Orientation:
Monitoring sexual orientation can be considered a sensitive area and people often question the benefits. However NHS Bolton recognises the value in collecting this information to ensure that lesbian, gay or bisexual patients are accessing quality services that meet their needs.
It is now unlawful to discriminate in employment and in the provision of goods and services on the grounds of Sexual Orientation. As such, monitoring information enables us to be clear that our services are fully accessible and responsive regardless of sexual orientation.
We recognise that sexual orientation can be a very sensitive area on which to collect data, particularly where it may be attached to patient records and not anonymous. Therefore, although Sexual orientation is a part of the PCT’s minimum requirements, on occasions it may be more appropriate not to ask this question.
Services should think about who has access to patient information and if patients could be unwillingly ‘outed’ to another service provider or agency. Only if there are significant concerns in relation to this, should data on sexual orientation not be collected.
However this does not mean that data on sexual orientation should NOT be collected because staff feel uncomfortable asking – this is a training need that can be addressed. For further guidance please contact the Equality & Diversity Manager on 01204 462015
Benchmarking
Currently the national census does not monitor sexual orientation which will also not be included in the next 2011 census. However, the Office for National Statistics will be including sexual orientation monitoring within its integrated household surveys. Current National estimates suggest that 7% of the population are Lesbian, Gay or Bisexual.
Religion & Belief:
It is now unlawful to discriminate in employment and in the provision of goods and services on the grounds of Religion and Belief. As such the use of monitoring information enables us to be clear that services are fully accessible and have no negative impact on a particular religious group.
Collecting data on Religion and Belief can be seen as a sensitive area, but this should not be the case and the benefits of collecting the information can be significant in highlighting issues that may not previously have been considered, as quite often it is assumed that a persons religion or belief is not relevant to the services we provide.
You should never make an assumption about a persons religion or belief based on race or appearance and it must always be the service users who chooses the category which best describes them - as we would for each of the other categories we collect.
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The Equality Monitoring Journey
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WHEN SHOULD WE EQUALITY MONITOR?
Customer satisfaction
· Through questionnaires: This is the most common form of patient engagement and data collection. Equality information should be collected as part of this process and data collected should then be disaggregated by equalities group.
By collecting this information and analysing it we are able to identify if there are any groups within the borough who have low levels of satisfaction in relation to aspects of our service delivery. This could identify if there are issues around accessibility, unmet need or communication difficulties etc.
· Customer complaints: By monitoring complaints received, any group over represented will be easily identifiable. By using this you may also be able to identify trends in complaints, which might help identify need for action in that area.
Employment & Service take up
· Ongoing Contact: This is the most useful form of data to collect as it allows us to monitor a persons complete experience through our service pathway or employment processes. By monitoring at first contact and then progression through a process, it allows us to look in detail at how different groups of people are affected from initial contact though to the final outcome.
For instance in employment, equality information is collected on job applications and this information is then anonymously analysed to by groups to see if a proportionate number of people are applying, being shortlisted and appointed, compared to the local population.
This type of data is also extremely valuable as it can provides us with anonymous public health information – for instance the % of people with Type II diabetes that are Black & Minority Ethnic compared to the number of people accessing appropriate services.
· Episodic Contact: This is useful when contact with a service is fairly short term, limited or occasional. For example, a one off complaint or use of a family planning clinic.
· Sampling: sampling allows us get a snapshot of our service users at a particular point in time. Sampling can measure purely take up of a service, but can also be used to measure satisfaction.
Although sampling will limit you to a snapshot, it may be repeated for comparison reasons to increase accuracy and reliability. The benefits of sampling are that it is completely anonymous and is not attached to a persons permanent record.
For more information and guidance on engagement styles and approaches please see NHS Bolton Communication and Engagement Toolkit.
HOW TO MONITOR?
Equality monitoring involves collecting data that can be very personal and consequently people may be reluctant to give this and could be suspicious of why you are collecting it.
To ensure that individuals feel comfortable providing this information, it is imperative that service users understand why this information is being collected and how it will be used. This therefore means that frontline staff asking for this information should be fully aware of what they are asking & why.
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HOW CONFIDENT CAN YOU BE IN YOUR RESULTS?
Unless you are able to monitor all your customers, you will never be 100% confident of your results. The most commonly used confidence level is 95%. Your margin of error will vary depending on how many responses you get back from your monitoring exercise. The better the response rate, the lower the margin of error.
If you are delivering a universal service where your population is large, your response rate needs only to be about 1% to get meaningful results. However, where a service has a smaller user population, response rates in comparison need to be higher and it is usual to survey all users.
However, low levels of responses should not be seen as a reason to not collect the data. Unless we start to collect data we will never reach a stage where we have a good enough response rate to meaningfully analyse this information. This means that it might take a couple of years to reach the level of data needed, so the earlier we start collecting it, the better.
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Additional help and support
To accompany this guidance the Equality & Diversity Manager is running training sessions on Equality Monitoring as further support for staff. Details of this can be sought from the team on the details below.