Gateway to Homechoice Allocations Policy

Name of policies to be assessed

Gateway to Homechoice Allocations Policy 

1. What is the main purpose of the policies?

The main purpose of the policies is to allocate social housing according to need and ensure that housing need assessment is fair and does not discriminate on unreasonable grounds. 

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

• The policy aims to assess the needs of everyone who makes an application for housing based on their individual circumstances. Each applicant will be placed into a Band between A and E, with those who are in most urgent housing need will be placed in Band A. Priority is also given to applicants who will release accommodation in high demand, for example, applicants who want to downsize.
• The policy aims to promote equality and equal opportunities for access and participation by everyone and to assess applications for housing against the same criteria.  

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

The policy has now been reviewed and a number of changes have been made to the policy. Areas for review were identified in the following ways: 

• Analysis of trends and data from the housing register and lets 
• Consultation with the Project Board 
• Consultation with frontline staff 
• Carrying out a formal review meeting with representatives from all local authority partner and finalising proposed changes to wording with this review group 

In January 2022, the Department for Levelling Up, Housing and Communities issued new a new Code of Guidance called, Improving access to social housing for victims of domestic abuse.  This guidance clarifies how local authorities should support and assist those who are fleeing domestic abuse. This guidance has also been considered while developing and updating the Allocations Policy. 

Changes made to the Allocations Policy include: 

• Adding explicit wording on Sensitive lets and when they can be used; 
• Clarifying inconsistencies in the homelessness sections of the policy; 
• Updating wording on domestic abuse and how local authorities support victims to access housing when they are fleeing abuse.  

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:

• Applicants for social housing who perceive themselves to be in need of social housing, some of whom are very vulnerable 
• Local authorities and registered housing providers will also need adhere to the content of the policy to ensure that it is consistently applied across the Gateway area of operation 

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

• To meet the legal requirements for letting social housing 
• To assess all customers fairly based on their need for housing and to enable those in greatest housing need to access social housing  
• To make best use of existing housing stock 
• To provide a consistent lettings process across the sub region, so properties are let in a fair and transparent way 
• To provide increased choice and information to customers in the allocation of social housing 
• To support vulnerable customers accessing available homes 
• To ensure that customers are not discriminated against, whether directly or indirectly 
• To improve mobility across the sub region by allowing customers to apply to be housed in any of the seven local authority areas 
• To promote social inclusion and help achieve sustainable communities 

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

Local authority partners are:  

• Babergh District Council; 
• Braintree District Council; 
• Colchester City Council; 
• East Suffolk Council; 
• Ipswich borough Council; 
• Maldon District Council; and 
• Mid Suffolk District Council. 

Registered housing provider partners are:  

• Abbeyfields Housing 
• Anchor Hanover 
• Asett Homes 
• Broadland Housing Association 
• CDS Coop 
• CHP 
• Clarion 
• Cotman Housing Association 
• Eastlight Community Homes 
• English Rural Housing  
• Estuary 
• Flagship Homes (including Suffolk Housing) 
• Guinness 
• Habinteg 
• Haig Housing 
• Hastoe 
• Havebury Housing 
• Home Group 
• Housing 21 
• HS Property Group 
• London and Quadrant Housing 
• Moat 
• MS Oakes 
• Notting Hill Genesis 
• Orbit Group Ltd 
• Orwell Housing Association 
• Papworth 
• Peabody  
• Rex Housing 
• RM Tubby 
• Riverside 
• Saffron Housing Trust 
• Sage Housing 
• Sage Rented 
• Salvation Army Housing Association 
• Sanctuary Housing 
• Swan Housing 
• V & F Homes 
• Winsleys 
• Winnocks & Kendalls 

7. Relevant information, data, surveys or consultations

• General monitoring is carried out by the scheme’s project board every quarter to ensure that the scheme is running effectively and that properties are being let to those in need  
• An annual report on the scheme is also published and available on the customer website 

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 allocations policy adheres to the 2010 Equalities Act and allows for a consistent, fair and transparent approach to making social lettings which takes account of each person’s need for social housing.  
• The scheme and policy are overseen by a Project Board, which regularly monitors available equalities data from the scheme.  
• Applicants to the scheme are assessed and prioritised according to their need for housing. Where applicants have been subject to harassment in their current/previous homes, they can be given a high priority on the housing register.   
• People with disabilities are assessed and may be given a higher band due to their medical needs 
• Those in Ethnically Diverse Communities may be given high priority awards in cases of harassment 
• Older people have access to specialist accommodation to meet their needs 
• There is clear information on the Gateway to Homechoice website which outlines how clients’ housing applications will be prioritised as well as showing which properties are let to which type of applicant each week including an average waiting time tool.  

9. 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) 

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.  

The law regarding the allocation of affordable housing sets out that Allocation Polices must have a means for determining priority between applicants and specifies five groups of applicants who must be awarded reasonable preference over other applicants, within the allocation scheme. The groups particularly relevant to improving health and reducing health inequalities are: 

• Applicants occupying unsanitary or overcrowded housing or otherwise living in unsatisfactory housing conditions. 
• Applicants who need to move on medical or welfare grounds (including grounds relating to disability). 

Housing legislation also gives local authorities the ability to give additional preference to applicants if they meet the statutory reasonable preference categories and have an urgent housing need. The Gateway to Homechoice Allocations Policy gives additional preference to the following groups which would help improve the health of and reduce health inequalities:  

• Applicants who need to move urgently because of a life-threatening illness or sudden disability - will be assessed for additional  
• priority on medical and/or welfare grounds 
• Families with severe overcrowding which poses a serious health hazard –will be assessed for additional priority on medical or welfare grounds. 

There is extensive literature on the relationship between housing and health. The Allocations Policy seeks to give access to housing which is of good quality and design; affordable; has security of tenure and can be a setting for care, all of which can impact directly on health, as well as indirectly on health determinants 

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 Business Plan sets out how the council will provide well managed, maintained and safe social housing according to legislation and government policy which helps to improve and reduce health inequalities for tenants and leaseholders.

Age - older people (60+)

Positive impact

• Priority for sheltered accommodation gives greater opportunity and choice of housing
• Older applicants who wish to downsize are also given high priority on the housing register to enable them to move as quickly as possible 

Negative impact

Primary access to the application and bidding process is via a website which those over 60+ may not have regular access to or may not feel comfortable using this type of technology 

Age - younger people (17-25) and children (0-16)

Positive impact

• Under 16s are treated as dependent children and are therefore in a priority need group 
• 16 and 17 year olds are also considered to be in priority need 
• Those who are under 21 years old who were in local authority care between the ages of 16 and 18 and those aged 21 and over who are vulnerable as a result of leaving local authority care are in a priority need group 
• 17 – 25 year olds can also access supported housing if this best meets their housing need. 

Negative impact

• Under 16s may be expected to share a bedroom with a sibling of the same sex even if there is a large age gap between them

• Under 18s cannot legally hold a tenancy

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

Positive impact

• Physical needs can be taken into account during the application process and applicants can be given a higher banding than usual due to their physical needs. 
• Adapted properties are also available to those who need it 
• Some new properties built within the Gateway adhere to the Lifetime Homes standards 
• Sensory needs can be taken into account during the application process and applicants can be given a higher banding than usual due to their sensory needs. 
• Adapted properties are also available to those who need it 
• Some new properties built within the Gateway adhere to the Lifetime Homes standards 
• Learning disabilities can be taken into account during the application process and applicants can be given a higher banding than usual due to their learning disability
• Mental health needs can be taken into account during the application process and applicants can be given a higher banding than usual due to their mental health needs 

Negative impact

• Some properties will be inaccessible to those with physical disabilities – e.g. top floor flat with no lift 
• Live-in help will not automatically be considered to be part of a household but would be added as a household member once the household has provided evidence of the need for a live-in carer. 
• The number of fully wheelchair accessible properties is very small and so those with physical disabilities may be waiting for a long time for long-term suitable accommodation. 
• Some properties will not be appropriate for those with sensory needs and applicants will need to be made aware of this and how they can identify suitable properties. 
• Online scheme could disadvantage this group which may find it more difficult to access the service.  
• Vulnerable applicants may not be shortlisted for certain properties, which are subject to a sensitive lets – this is to safeguard vulnerable applicants from risks which could be posed by other tenants. 

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

Positive impact

• The policy may particularly help to protect Black and Minority Ethnic Groups from harassment through high priority awards on welfare grounds
• The policy may particularly help to protect this group where they have been the victim of harassment

Negative impact

• Potential literacy difficulties making it harder to complete the online form.

Language – English not as a first language

Positive impact

• The policy may particularly help to protect Black and Minority Ethnic Groups from harassment through high priority awards on welfare grounds
• The policy may particularly help to protect this group where they have been the victim of harassment

Negative impact

• Potential literacy difficulties making it harder to complete the online form.

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

Positive impact

• Women who are pregnant and those who dependent children are in a priority need group  
• This group may also benefit from an additional bedroom housing need being awarded as a result of pregnancy or childbirth

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

Positive impact

• Applicants could be awarded a higher banding under the welfare award if they need to move due to suffering from religious harassment  

Sex – Men and Women

Positive impact

• 90% of those currently serving in the armed forces are men and this group is given additional preference for housing within this scheme
• Men who are victims of domestic abuse are now considered to have a ‘priority need’ and so will be owed a re-housing duty by the local authority if they have fled from their existing/previous accommodation. 
• Priority is awarded to families with children, and women are disproportionately the main carer of dependent children
• Women who are victims of domestic abuse are now considered to have a ‘priority need’ and so will be owed a re-housing duty by the local authority if they have fled from their existing/previous accommodation
• If a woman has fled domestic abuse and previously held a social housing tenancy, they must be given an equal tenancy type in their new property

Negative impact

• Men with access to children, where the child does not permanently reside with them may not be awarded priority for an additional bedroom under the policy. 

Gender reassignment - Transgender/Transsexual

Positive impact

• The policy helps to protect this group from harassment through high priority awards on welfare grounds 

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

Positive impact

• The policy helps to protect this group from harassment through high priority awards on welfare grounds 

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

Positive impact

• The lettings made through this scheme take account of individual needs and help to ensure that none of the protected characteristics are discriminated against either directly or indirectly.   

11. How negative impacts be minimised or removed?

Older people - negative Impact

Some older people do not have the knowledge or access to benefit from the online system.

Method to minimise or remove

Local authorities provide a telephone call service to customers who are experiencing difficulties in completing the online application form. 

Officers telephone the customer and work through the questions and complete the application form on behalf of the customer. Officers may also bid on behalf of customers who can’t bid for themselves

Under 16s – negative impact 

Under 16s may be expected to share a bedroom with a sibling of the same sex even if there is a large age gap between them.

Method to minimise or remove

Children are often expected to share bedrooms. If children are over the age of 10 and the opposite sex to their sibling, they are then entitled to their own bedroom

17-25s - negative Impact

17 year olds can’t hold a tenancy 

Method to minimise or remove

If a 17 year old has a guarantor who is over 18, they could hold the tenancy in trust for the 17 year old.

People with disabilities (physical and sensory) - negative impact

Some properties will not meet be accessible to or appropriate for those who have physical/sensory disabilities

Live-in help will not automatically be considered to be part of a household. 

Method to minimise or remove

Local authorities will liaise with applicants to ensure that they are able to bid for properties which have already been adapted or can be adapted to meet an applicant’s needs 

Although live-in help will not automatically be considered part of the household, extra rooms for carers will be subject to assessment in conjunction with social services’ supporting evidence.

People with learning disabilities - negative impact

Online scheme could disadvantage this group which may find it more difficult to access the service. 

Method to minimise or remove

Live-in help will not automatically be considered to be part of a household.  

Local authorities will support those who are experiencing difficulties in completing the online application form or can complete the form on behalf of the customer

Officers may also bid on properties on behalf of applicants

Although live-in help will not automatically be considered part of the household, extra rooms for carers will be subject to assessment in conjunction with social services’ supporting evidence.

People with mental health needs - negative impact

Vulnerable applicants may not be shortlisted for certain properties, which are subject to a sensitive lets – this is to safeguard vulnerable applicants from risks which could be posed by other tenants.

Method to minimise or remove

If a property is subject to a sensitive let, this will be clearly shown on the property advert so that applicants are aware of all relevant property details.

Ethnicity – Gypsies/Travellers

Potential literacy difficulties with this group making it harder to complete the online form

Method to minimise or remove

Local authorities can offer telephone applications to those who cannot complete the form themselves.

People who do not have English as a first language - negative Impact

Online scheme could disadvantage this group.  Potential issues of accessibility and possible difficulty around understanding how the scheme operates.

Method to minimise or remove

The Gateway website and application form can be translated into all languages so to enable those who don’t have English as a first language to understand and participate in the scheme

Local authorities will also provide links to local community groups which can help those who need it to complete application forms/explain the scheme to them 

Language line is also available to customers who need translation and interpretation services.

Men - Negative Impact

Men with access to children, where the child does not permanently reside with them are not awarded priority under the policy.

Method to minimise or remove

Men with access to children are offered advice and information on all housing options. 

Additional general points 

• Each case is assessed on an individual basis to avoid discrimination against protected characteristics 
• Local Authorities identify vulnerable customers and send out newsletters giving details of properties in each cycle.  The Local Authorities can also then place bids for properties on behalf of customers.  

12. Could the policy discriminate⁵ against any ‘protected characteristic’ either directly or indirectly?

No. Applicants are only assessed according to their need for housing and against the same criteria. The policy does not discriminate against any protected characteristics either directly or indirectly.  

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 (B). Negative impacts have been identified but have been minimised or removed  - Action is to sign off screening and finish.

14. Name and job title of person completing this form

Claire Beckett – Gateway to Homechoice Coordinator 
Karen Paton – Housing Strategy Officer 

15. Date of completion

9 June 2021

16. Date for update or review of this screening

When the Allocations Policy is next reviewed or within three year’s time (June 2025) whichever is sooner.  

• [1] National Census 2021 ethnicity categories are: English, Welsh, Scottish, Northern Irish or British; Irish; Gypsy or Irish Traveller; Roma; Any other White background (White); White and Black Caribbean; White and Black African; White and Asian; Any other Mixed or Multiple backgrounds (Mixed or Multiple ethnic groups); Indian; Pakistani; Bangladeshi; Chinese; Any Other Asian background (Asian or Asian British); Caribbean; African; Any other Black, Black British or Caribbean, Any other Black, Black British or Caribbean background (Black, Black British, Caribbean or African); Arab, Any other ethnic group (Other ethnic group).
• [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 is different from the needs of persons who do not share it, and (c) encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately low.
• [4] This involves having due regard, in particular, to the need to (a) tackle prejudice, and (b) promote understanding.
• [5] 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 practise would nevertheless disadvantage people on the grounds of their `protected characteristic’.