Garage Allocation and Arrears Policy

Initial Equality Impact Assessment

At Colchester City Council we have a corporate approach to equality and diversity that reinforces the importance of providing equal opportunities to potential and existing employees. Through the employment of committed and motivated people, we can deliver excellent customer services and improve the reputation of the Council as an employer of choice.

Name of policies to be assessed

Garage Allocation and Arrears Policy

1. What is the main purpose of the policies?

The main purpose of the policies is to:

• To set out the allocation priority for council garages to ensure this is applied consistently and fairly.
• Detail how garage accounts in arrears will be managed.

2. What main areas or activities does the policies cover?

The allocation of Council garages and management of rent accounts.

3. Are there changes to an existing policy being considered in this assessment?

There are no changes to an existing policy being considered in this assessment.

4. Who are the main audience, users or customers who will be affected by the policy?

The main groups who will be affected by the policy are:

• Council and Colchester Borough Homes officers
• Current garage tenants
• Future garage tenants

5. What outcomes does the Council want to achieve from the policy?

The outcomes that the policy should achieve are:

• To manage the allocation of Council garages. 
• To manage garage rent accounts in particular when they fall into arrears.

6. Are other service areas or partner agencies involved in delivery?

Colchester Borough Homes

7. Relevant information, data, surveys or consultations¹

No relevant information

8. The ‘general duty’

The ‘general duty’ states that we must have “due regard” to the need to:

1. eliminate unlawful discrimination, harassment and victimisation
2. advance equality of opportunity between people who share a ‘protected characteristic²’ and those who do not³
3. foster good relations between people who share a protected characteristic and those who do not⁴

Not all policies help us to meet the ‘general duty’, but most do.

This policy helps us to meet the ‘general duty’ by:

• The policy does not specifically help us to meet the duty.

The policy helps us to ‘advance equality of opportunity…’ in the following way(s):

• Priority is given to disabled applicants, this is because if they weren’t there is less possibility to be allocated a garage near to their home particularly in areas of high demand. Also, the impact on a disabled person is likely to be greater than that of an able-bodied person if their car is stolen or damaged.

The policy helps us to ‘foster good relations…’ in the following way(s):

• The policy does not specifically help us meet the duty.

9.  Public Sector Equality Duty

The Council has an important role in improving residents’ health under the Health and Social Care Act 2012. This relates to both its ‘core functions’ (such as housing, leisure, green spaces and environmental health) and to its ‘enabling roles’ (such as economic 
development, planning and engaging with communities)⁵. The Council recognises that its Public Sector Equality Duty and its role in improving health are interrelated and mutually supportive. This is especially true across the ‘protected characteristics’ of age and 
disability. 

“Health inequalities are the unjust and avoidable differences in people's health across the population. They come from the unequal distribution of income, wealth and power and influence the wider determinants of health such as work, education, social support and housing. Currently, in England people living in the least deprived areas will live around 20 years longer in good health than those in the most deprived areas. Reducing health inequalities means giving everyone the same opportunities to lead a healthy life, no matter where they live or who they are."

Where applicable, explain how this policy helps us to improve health/reduce health inequalities for residents:

• The policy does not specifically help us to improve health/reduce health inequalities for residents

10. Disproportionate impacts

This section helps us to identify any disproportionate impacts. We will indicate whether the policy is likely to particularly benefit or disadvantage any of the 'protected characteristics'.

The following applies to all protected characteristic groups:

Age - older people (60+), younger people (17-25) and children (0-16)

Positive impact

Disability – physical, sensory, learning, mental health issues, other

Positive impact

This group will benefit from the higher priority given when allocating garages.

Negative impact

N/A

Ethnicity⁶- White; Mixed or Multiple ethnic groups; Asian or Asian British; Black, Black British, Caribbean or African; Other ethnic group

Positive impact

N/A

Language – English not as a first language

Positive impact

N/A

Pregnancy and maternity - Women who are pregnant or have given birth in the last 26 weeks

Positive impact

N/A

Negative impact

N/A

Religion or belief - People with a religious belief (or none)

Positive impact

N/A

Sex – Men and Women

Positive impact – Men

N/A

Positive impact – Women

N/A

Negative impact

N/A

Gender reassignment - Transgender/Transsexual⁷

Positive impact

N/A

Sexual Orientation – Straight/Heterosexual, Gay or Lesbian, Bisexual, Other sexual orientation

Positive impact

N/A

Marriage and Civil Partnership - People who are married or in a civil partnership

Positive impact

N/A

11. How negative impacts be minimised or removed?

No negative impacts identified.

12. Could the policy discriminate⁸ against any ‘protected characteristic’ either directly or indirectly? ⁹

No

Summary and findings of Initial Equality Impact Assessment

13. Confirmation of findings

There are four options to describe the finding of the EqIA:

1. No negative impacts have been identified – Action is to sign off screening and finish.
2. Negative impacts have been identified but have been minimised or removed  - Action is to sign off screening and finish.
3. Negative impacts could not be minimised or removed – Action is to sign off screening and complete a full impact assessment – Section 2.
4. There is insufficient evidence to make a judgement - Action is to sign off screening and complete a full impact assessment – Section 2.

The findings and action are confirmed as (A). No negative impacts have been identified. The action is to sign off screening and finish.

14. Name and job title of person completing this form

Suzanne Norton – Housing Client Co-ordinator

15. Date of completion

17 February 2022.

16. Date for update or review of this screening ¹⁰

Upon change or revision of policy or February 2025.

• [1] Click on Customer Insight for more information. The Council’s surveys and consultations include ‘equality monitoring information’ to help us identify any particular concerns or views expressed by any particular group or ‘protected characteristic’. It can also help us to assess how representative of our customers the respondent group is. Local data on the ‘protected characteristics’ is available on this page of Sharepoint.
• [2] The Equality Act’s ‘protected characteristics’ include age, disability, gender reassignment, pregnancy and maternity, race, religion or belief and sex and sexual orientation. It also covers marriage and civil partnerships, but not for all aspects of the duty.
• [3] This involves having due regard, in particular, to the need to: (a) remove or minimise disadvantages suffered by persons who share a ‘protected characteristic’ that are connected to that characteristic; (b) take steps to meet the needs of persons who share a relevant ‘protected characteristic’ that are different from the needs of persons who do not share it, and (c) encourage person
• [4] This involves having due regard, in particular, to the need to (a) tackle prejudice, and (b) promote understanding.
• [5] The King’s Fund: The district council contribution to public health: a time of challenge and opportunity, 2015
• [6] National Census 2011 categories are: Bangladeshi, Indian, Pakistani, Other Asian (Asian or Asian British), African, Caribbean, Other Black (Black or Black British), White and Black African, White and Asian, White and Black Caribbean (Mixed), British, Irish, Other White (White), Chinese, Other (Other Ethnic Group).
• [7] The ‘protected characteristic’ of gender reassignment is defined by the Equality Act 2010 as “a person proposing to undergo, is undergoing or has undergone a process (or part of a process) for the purpose of reassigning the person's sex by changing physiological or other attributes of sex.” This is a personal process that may involve medical interventions such as counselling, psychotherapy, hormone therapy or surgery, but does not have to.
• [8] The Council has a general duty to ‘eliminate unlawful discrimination, harassment and victimisation’. Direct discrimination occurs when a person is treated less favourably than another in a comparable situation because of their ‘protected characteristic’ whether on grounds of age, disability, pregnancy and maternity, ethnicity; religion or belief; sex (gender), sexual orientation, or marriage and civil partnership. Indirect discrimination occurs when an apparently neutral provision or practice would nevertheless disadvantage people on the grounds of their ‘protected characteristic’.
• [9] If you answer ‘yes’ to question 11 (above) you will need to complete the following section and go on to complete Section 2 in order to conduct a full Equality Impact Assessment.
• [10] This is normally three years, but not always: You may know that the policy itself will be reviewed earlier in which case the EqIA should be reviewed at that time. Or, in the case of a five year strategy, you may want to have a review date of five years. In the case of a “one off” decision, such as closing a service, a review date may not be needed - in which case you should indicate ‘N/A’. In any event, the review date should be brought forward if you receive information or feedback which raises new concerns, or if the public policy context changes. You can speak to the Equality and Safeguarding Co-ordinator for more advice.