Action

Who/how/when

Owner

Progress

All job descriptions and work objectives will include a diversity dimension. Guidance on how to do this has been posted on the Diversity pages of our intranet (Connect).

All staff. Objective setting in March / April 2009 and subsequently in 2010 and 2011.

Directors

All business areas have confirmed that job objectives include a diversity dimension. Once objectives are online we can undertake a sampling exercise to ensure that objectives are proportionate and appropriate. Interim reviews are being used to review diversity objectives.

A programme of impact assessments will be implemented in each business area and action plans created. Progress against the plans will be monitored. Plans will include projects that span business areas.

All HoDs to ensure assessments are carried out in their areas. Project managers will ensure that all project plans include EQIAs. The Diversity Champion's Network will monitor the quality and outcome of assessments.

Directors

Equality Impact Assessments (EQIA) are being carried out. They are listed in the in the 2009-10 Board diversity update and have been published on Connect. Key EQIA work is as follows;

• We are currently working on version 6 of our EQIA that accompanies the Strategic Review. Each version has been published on Connect and the final version will be published on our web site.

• In 2010 we carried out a full EQIA on our plans to increase our online services activity, which included a public consultation and this has been published on our web site.

• A full EQIA was conducted on our Compliance risk and proportionality framework. As a result of this we produced guidance for case workers on equality and diversity considerations in our case work.

Finalise and publish the SES ensuring that all Directorates have meaningful action plans

The Diversity Manager will publish the plan and conduct an external consultation in the summer of 2009 with a view to full implementation in January 2010.

The Diversity Manager

The scheme was finalised and published in January 2010 and the actions contained in this action plan have been cascaded through local action plans in individual divisions.

Action

Who/how/when

Owner

Progress

All Directorates will draw up a detailed action plan for their business areas which will set out their equality and diversity activities. These will form part of their sub-plans.

Identified Diversity Champions to draw up plans with the Diversity Manager.

Directors

Compliance and Policy and Effectiveness have a detailed SES setting out our diversity and equality priories which underpin all the work we undertake.Charity Services has embedded equality and diversity in their business plan.The HR people plan contains a specific diversity section.

All staff will undertake training in equality, diversity and cultural awareness.

Trainers have been appointed and training will begin in April 2009.

Diversity Manager

Equality and diversity mandatory training was completed in October 2009 (mop up training in 2010). In 2010, we carried out EQIA training and workshops on managing unconscious bias. In 2011 we will be rolling out a programme of disability awareness training, with a particular focus on hidden disabilities.

All business areas will nominate a diversity champion who will be responsible for maintaining the profile and importance of equality and diversity and reporting on progress against this action plan.

The Champions Network will be in place by the end of October 2009 and the Diversity Manager will work with them to deliver against the actions in the scheme.

Diversity Manager

All Directorates have more than one Diversity Champion and they share the work across the Directorate. In Compliance and Charity Services equality and diversity is raised at each team meeting.

Equality and diversity issues will be on the agenda of each Directors Senior Team Meetings to ensure that issues continue to be discussed.

Directors and senior managers will include diversity on agendas from November 2009.

Directors / All managers

Diversity is a standing item at Compliance, Charity Services and Policy and Effectiveness SMT meetings. On 16 June 2011, the newly constituted SMT (which is a strategic review outcome), fully considered the equality and diversity implications of new functional business plans prior to them being put out for staff consultation.

We will monitor progress on diversity issues through the performance appraisal process and corporate monitoring processes

HR will compile a report at the end of the reporting year 2009-10 following analysis of a selection of performance appraisals which will compare box markings across the diversity strands. If any equality and diversity issues are identified appropriate action will be taken.

HR and the Diversity Manager

A box marking analysis has been undertaken and the results were discussed at the Diversity Steering Group (DSG) in February 2010. A summary is included in the 2009-10 Board update. We will continue to monitor all box marking results for equality issues.

Diversity and equality issues will be included for discussion within the reconvened Commission Policy Group.

The Policy Diversity Champion will oversee this activity, ensuring that equality and diversity issues across all diversity strands have a profile

Policy

Policy discussions with external groups are organised as and when required. For example, the advisory Group on Faith, a focus group on charities and investments, a focus group on charities and political campaigning. In all of this activity equality and diversity issues are incorporated as appropriate. For example implications of Equality Act for faith based charities.

We will develop and maintain links with the EHRC to ensure that the Commission is kept up to date with developments in the law and policy on equality and diversity.

The Head of Policy Development will lead on equality and diversity in this area and will ensure that regular updates are provided to the Diversity Manager and other business areas as appropriate.

Policy

Policy and Legal representatives have met with the EHRC and are collaborating on producing guidance for charities on the implications of the new Equality Act 2010. Summary guidance is on the website and further guidance will be available soon. We are also liaising with the Government Equalities Office and will continue to keep abreast of Equality Act implementation plans.

The Board and our Board Diversity Champion will ensure that robust plans exist to meet Government diversity targets and that diversity delivery plans are fully integrated into business plans.

The Governance Diversity Champion and the Diversity Manager will oversee this activity and ensure that the Board is fully apprised of relevant information.

Head of Governance

The Board receives regular diversity updates, which are published on our web site, and has been actively involved in setting the strategic direction through the SES.

Diversity progress will be monitored through Board approval of Corporate Plans and Board assessment of annual diversity reports.

The Diversity Manager will produce regular reports for the Board using information from divisional reports and the Diversity Champions Network.

Diversity Manager and the DG Diversity Champion

The Board received the first report on progress against this action plan in November 2010 and will continue to receive regular reports. The Board will also oversee the transition from the SES to the new framework once our strategic review is complete and we know what the Governments plans are in respect of the specific duties.

The DG and the Board will oversee the delivery of the Commission's Equality Impact Assessment Programme.

Regular reports will be provided by the Diversity Manager

Diversity Manager

Update on EQIA work is in the 2009-10 Board Update and the Board has inputted into the EQIA that accompanies the Strategic Review at each stage of the process.

All directorate plans will contain diversity objectives and outcomes.

As a minimum all sub-plans will contain a commitment to appointing a local diversity champion and reporting on progress against this action plan through business reporting. An annual audit of diversity and equality provisions will be undertaken by Performance and Planning.

Performance and Planning

Diversity objectives and outcomes are in Compliance and Policy and Effectiveness's Annual Plans 2010-11 and in Compliance's part year plan to September 2011, and in the Commission's People Plan. Other members of staff have specific equality and diversity objectives, such as HR and the Diversity Manager.

We will disseminate information and experience gained in equality, diversity and cultural awareness as a result of our engagement with stakeholder groups.

All areas of the business, but in particular the Faith and Social Cohesion Unit (FSCU) and Charity Engagement will provide regular updates to the business.

All Divisions

Neither Charity Engagement nor FSCU exist anymore. However, equality and diversity information is being shared with the Diversity Manager and through the Diversity Champion's Network. Also, there is comprehensive information available now on Connect.

We will develop a range of tailored staff forums providing opportunities for staff to engage on issues.

The Internal Communications Manager will put forward proposals in the second quarter of the 2009-10 reporting year.

Internal Communications Manager

The Connect upgrade project is looking to enhance our ability to engage staff on-line. We have also introduced an internal Strategic Review on-line discussion forum, which staff can use to comment on Strategic Review plans and options, including any equality issues.

Action

Who/how/when

Owner

Progress

Accessibility will be a key factor in determining what buildings we occupy, use for events etc and will be a priority in all equipment, electronic systems, services and written documents

Accessibility issues will be identified through EQIAs and will be regularly reported to the DG.All new web pages and online service applications to be at least W3C Double A compliance.

Directors and the Diversity Manager

Abilitynet have assessed our internal systems for accessibility and made recommendations. The Commission's Database Replacement Project has also made use of Abilitynet and have tested the new database, including tests for accessibility with the help of staff with disabilities.Abilitynet held workshops on each site on 1 July 2010.An accessibility page has been created on our intranet and contains guides on using and making adjustments to our systems. These were produced in association with Abilitynet.

Future Web Accessibility - we will continue to develop our accessibility in line with e-accessibility guidelines.

Further activity in on -line and web developments will require an analysis of the work involved to meet new standards to be recommended by the EU WCAG 2.0.

All internal and external development managers

Software specifications mandate accessibility requirements. Products are tested against the appropriate standard and their integration with specialist accessibility tools. Recent developments that have applied this process include new web forms and online service enhancements.

All outreach events will be planned so that they are accessible to all and reasonable adjustments made where appropriate

We will make reasonable adjustments and provide assistance for those who need help in accessing our services.

All business areas that engage in outreach ensure that all events are accessible, checking timings of events with respect to religious holiday dates and the accessibility of venues - asking attendees in advance of special needs. Reasonable adjustments made as required - e.g. BSL interpreters at one event.Policy held a workshop for charities advancing religion which catered for the dietary and other needs of attendees from different religious faiths.

All internal and external communication activity will comply with Stop Think Write principles.

Guidance will be drafted on accessibility and communication. The Diversity Champions Network will oversee this activity.

Diversity Champions and the Diversity Manager.

Compliance ensures that major publications are sent to the Plain Language Commission for comment. f. We actively consider diversity issues when assessing concerns and at all case stages. An accessibility leaflet is now issued with letters in Compliance on our first engagement with trustees asking if they have any difficulties in understanding our correspondence or if they need us to take any special measures.
Stop Think Write principles are embedded in all business areas and we have produced an “easy read” version of the Essential Trustee for trustees with a learning disability.As part of our strategy to enhance website self-service, training is underway in Policy Development and Review around communicating complex information in a clear and accessible way.The redesign of the website, which took place in March 2010 incorporates “plain language” principles for web text and guidance.

All new and existing forms associated with all functions and divisions will be tested for accessibility before being released for use, including the use of on-line surveys.

In most cases forms are for internal use in HR, accounts and IS but with technology and e-enabled working becoming more prevalent we need to ensure that all business areas are aware of accessibility issues.

IS will own accessibility issues in relation to forms and electronic working but each division will have responsibility for keeping IS informed.

There is now an accessibility section on the intranet and all user testing includes people with disabilities.The Policy Guidance team, in redesigning OGs, have worked with the Disability Forum and a user with a visual impairment to ensure good accessibility

All open event papers will be written in accordance with Stop Think Write principles and wherever possible will be available in different languages where requested.

The Governance team will ensure that accessibility requirements are fully considered.

Head of Governance

We will routinely assess and address any barriers to accessing our services, working collaboratively with colleagues across the Commission.

This activity will be coordinated by the Diversity Champions Network.

Diversity Manager

he Diversity Manager has oversight of all EQIA work and works with all business areas to identify accessibility issues. She regularly consults with the Disability Forum and the DTUS.

We will develop a Welsh Language Scheme in conjunction with the Welsh Language Board and develop our Welsh Language services in pursuance of our obligations under the Welsh Language Act 1993.

This activity will be overseen by the Commission's office in Wales

Head of the Wales Office

Our Welsh language scheme was published in May 2010.

Action

Who/how/when

Owner

Progress

We will monitor customer experience through actively seeking customer feedback and where necessary will provide training and guidance to our staff. This will include equality, diversity and cultural awareness feedback.

All customer facing divisions will use a corporate customer questionnaire at case closure which will be analysed and findings reported to the DSG.

Directors and customer facing divisions.

Charity Services send out customer questionnaire to all newly registered charities and at case closure in case working sections. Responses are analysed monthly for diversity issues.In Compliance a revised Compliance Customer Survey (for trustees) has been drafted which now includes questions on fairness and diversity. This was launched in March 2011. Feedback will be monitored and advice taken from the Diversity Manager on any further action necessary.Operational Guidance (OG) now has a feedback form which includes a section about accessibility. The same approach is being trialled for small charities web guidance.

Through training and monitoring we will ensure that our staff, customer interface, policies and communications are applied consistently and fairly.

All divisions have responsibility for ensuring that we apply fair and consistent standards and the diversity champions will assist in developing consistent methods for measuring this.

Heads of Division

Training is being developed in handling difficult situations, which will include dealing with diverse customers and communication issues.RTN is currently launching case handling workshops to ensure consistency across the division.We participated in Deaf awareness week in June 2010.Policy provided training to staff in FSCU to help them advise applicants seeking to register as charitable Mosques

Equality, Diversity and cultural awareness will form part of the Compliance Quality Review and Improvement Programme.

The Compliance diversity champions will work with managers in Compliance to embed equality and diversity considerations into processes.

Head of Compliance

In Compliance the case work quality review system has been reviewed and a new system is being piloted. This incorporates appropriate Assessment of our performance in demonstrating an awareness and a practical application of equality and diversity issues during investigations We have updated our Staff Desk Guidance to ensure that reference is made to our obligations and commitment to treat everyone fairly. Training has taken place to ensure staff awareness.

All customer complaints containing allegations of discrimination or bias will be dealt with in accordance with the Commission's policy on allegations of inappropriate behaviour.

HR will monitor this activity and ensure that the Commission's policy on dealing with such allegations is adhered to.

Director of Charity Information and Corporate Services 

Policies have been drafted and are in the process of being finalised and published.

We will monitor through our quality review processes in Charity Services how we have handled our consent and advice work to ensure that we are acting consistently and fairly. Any instances of concern will be immediately escalated to a Head of Division and discussed by the senior management team.

All staff conducting quality reviews will be made aware of this and receive guidance and support from the Diversity Manager. Records will be maintained and action taken where necessary.

Charity Services Senior Management Team

Charity Services staff undertaking QRs have been trained in QR processes which include reference to our obligations under the SES.

We will consider and put in place any indicators or measures that will allow us to monitor whether customers are being treated fairly

The Diversity Champions Network will lead on this with advice from our internal auditors.

DSG

Our customer feedback questionnaires now contain an equality and diversity section. No other work has taken place on indicators and measures.

We will look at the feasibility of conducting a diversity and equality customer survey in 2009

This will be developed in Customer Service with input from the Diversity Champions Network.

Head of Customer Services and Diversity Manager

This has not been progressed due to uncertainty about the Commission's budgetary position.

Action

Who/how/when

Owner

Progress

Input will be sought from a range of charities from across the diversity strands in all engagement activity and stakeholder consultation.

The Diversity Champions Network will monitor this activity and advise in their areas as appropriate. Information on diversity issues arising out of visits to charities will be shared across the Commission.

All divisions engaging with charities and other stakeholders

As part of the Strategic Engagement programme we ensure that we were engaging with a diverse mix of charities, from across the diversity strands. A wide range of charities are invited to meet with the Commission as part of our programme of one to one meetings and we ensure that we invite a range of participants to our events to represent the diversity of the sector.As part of the development of the guidance for charities on the Equality Act, feedback has been sought from organisations which represent a wide range of stakeholders.

We will build effective working relationships with the EHRC and other bodies and develop a network of external contacts with whom we can work in partnership.

The DSG will receive reports at each meeting about the diversity of the stakeholders we have engaged with.

Diversity Manager

Contacts have been made through Legal and Policy and Effectiveness with the EHRC and the Diversity Manager is a member of the Civil Service Diversity Network. Contacts have been made with charities operating in equality and diversity and the Customer Network is being extended to include these.

Our website will have a discrete diversity section which contains information and signposting relevant to all diversity strands.

The Diversity Manager will work with the web publications team and this work will be completed by the end of the 2009-10 reporting year.

Diversity Manager

Work on this has begun and will continue throughout 2010-11.Our website has accessibility options (display for visual impairments, Browsealoud) and our commitment to equality and diversity has its own section (including diversity updates).

We will produce publications aimed at charities operating across the diversity strands which will be developed from information gathered through all activities.

All areas of the business involved in producing publications to include diversity considerations.

All relevant business areas

We have published summary guidance for charities on the charity exemption in the Equality Act 2010.

Action

Who/how/when

Owner

Progress

In all recruitment exercises we will consider the need for greater diversity and will use different methods to recruit, for example, in advertising using plain language to describe jobs, using specialist recruitment agencies and web sites and positive action initiatives.

All Directorates and divisions. HR will maintain monitoring data that can be used to inform managers involved in recruitment campaigns of any under-representation of particular groups. Managers will then consider diversity and equality issues at the beginning of recruitment campaigns.

Directors and HR

The Commission is not currently recruiting. However, if we are able to recruit for essential posts and through CSVACS we will be using positive action initiatives.A pilot talent management scheme is being considered so that where we have job opportunities that have to be filled internally we will have a talent pool to draw on.

We will develop a network of external selection panel members concentrating on BME members in the first year.

The Diversity Manager will lead on this by talking to contacts in the sector.

The Diversity Manager

While the Commission does have contacts that we have used in the past, there is currently an imposed Civil Service recruitment freeze so it is unlikely that we will be pursuing this in the way that was originally envisaged.

Action

Who/how/when

Owner

Progress

All managers will ensure that they take an active role in the progress and development of their staff and will act where any equality and diversity issues are identified.

Managers will ensure that all staff have a learning and development plan for the reporting year 2009-10.

Directors

Charity Services has a training and development plan in place for 2010-11.Policy and Effectiveness consider individual training needs at appraisal and objective setting and throughout year in one to ones.

We will strengthen our diversity staff forums so that there is a support network for staff across all diversity strands.

The Diversity Manager will work with the forums throughout 2009-10.

Diversity Manager

All Forums have had a re-launch event but they will continue to rely upon staff volunteering to participate.

Managers will ensure that the individual training and development needs of all staff will be considered on an individual basis, taking into account any particular needs, for example, disability.

All managers will consider this during appraisal and objective setting exercises in May 2009.

Directors

Charity Services consider individual training needs at appraisal and objective setting and throughout year in one to ones.

A service level agreement and guidance on making reasonable adjustments for our staff will be drafted.

The Diversity Manager will work with the Disability Forum and the Departmental Trades Union to produce the agreement and guidance by the end of June 2009.

Diversity Manager

The service level agreement has been implemented and is in use. It has been published on Connect. We will shortly be reviewing the policy to evaluate what has worked well and what hasn't using the experience of the recent office moves in Liverpool and the bedding in of new systems, for example, CRM.

Any incidents of our staff being treated disrespectfully when engaging with our customers will be recorded and appropriate action taken.

All incidents will be reported in accordance with the Commission's policy on Protecting Employees against Workplace Abuse

Heads of Division

The new policy will be in place before the end of July 2010 and thereafter any incidents will be reported in a standard format and statistics maintained by HR.

Through the Commission's Learning and Development strategy we will look at ways of developing the potential of all of our staff in their current and future roles.

The Learning and Development Manager and the Diversity Manager will work together and activity reported through the diversity champion's network so that good practice can be shared throughout the organisation.

Learning and Development Manager

The Learning and Development Manager has worked with the Diversity Manager in delivering equality and diversity training for all staff and providing training in how do conduct EQIAs.We have delivered a training course in managing unconscious bias.A new mentoring scheme has been introduced which includes plans for mentoring staff across the diversity strands.

There will be a planned programme of activity to improve the Commission's rating in the Stonewall Top 100 Workplace Equality Index.

The Diversity Manager will work with the staff LGB Forum, the Director of Charity Services and the Board Diversity Champion and will submit the Commission's application.

Diversity Manager

The Commission improved its position by 29 points in the 2010 index. A plan is in place for submission to the 2011 index.

We will provide feedback to our employees on staff survey results, consult widely on developing a new targeted action plan and monitor implementation.

The Head of HR Reward Strategy and Employee Relations leads on this activity. The Commission undertook its own survey in 2009 and participated in a wider Civil Service Survey in 2010.

Head of HR Reward Strategy and Employee Relations

Key results from the Commission's survey showed a major improvement in employee engagement rising from 5.3 in 2007 to 6.7 2009, but we identified the scores for BME staff were consistently lower than for other staff. We employed a consultant to conduct one to one confidential sessions with staff and as a result made some changes to our policies. The results of this activity however, showed that the scores did not relate to discrimination, but to manage competence in generalIn the Civil Service 2010 survey, the Commission scored well in some areas, but the scores on bullying and harassment and discrimination were too high. We are in the process of conducting confidential one to one sessions with any staff who wish to participate to see whether we can establish the reasons for this so that we can take appropriate action. Our disabled staff have already been through this process and we are waiting for the consultants report.

We will launch a careers web site providing prospective employees with a clear and positive view of the Commission and its work and the job opportunities available.

The site will be launched in May 2009.

Head of HR Operations

The new Careers Website was launched last Summer and has helped us to present a positive image of the Commission. At a time when there is a Civil Service recruitment freeze however, the impact of this is minimal at the present time.A report on positive action initiatives is contained in the 2010 Board update, which has been published on our web site.

We will undertake a bi-annual analysis of exit surveys and publish results and planned action on Connect.

Surveys will be analysed and reported on in September and March.

Head of HR Operations

Quarterly exit surveys undertaken. This data needs to be considered in the light of CSR requirements before any action plan is developed and published.

We will issue guidance on broadening the statutory right to flexible working.

The Head of HR Operations will lead on this activity in the first quarter of the 2009-10 reporting year.

Head of HR Operations

Guidance issued May 2009.

We will revise our maternity policy to reflect legislation affecting the right to accrue annual leave.

This will be a priority in the first quarter of the reporting year 2009-10.

Head of HR Operations

Policy revised and published September 2009.

We will develop and implement an Equal Pay Audit plan following the 2009 Equal Pay Audit.

This will be completed during the first half of 2009-10 reporting year.

Head of HR Reward Strategy and Employee Relations

An equality analysis of performance markings was undertaken. This was an action following from the Equal Pay Audit in 2008. This audit did not identify any major issues and found that the Commission was unusual in having equal pay between men and women. The box marking analysis for 2008-09 was discussed at DSG and DG.

We will carry out a Disability Survey and publish results and planned actions on Connect.

The survey will be carried out between August and September 2010. The results will be analysed in October and published on Connect in November.

Diversity Manager /DDPO/Disability Forum.

Survey completed and results analysed. As a result of this there are a number of actions being progressed, including disability awareness training and all disabled staff were offered the opportunity to speak confidentially with an independent consultant. We are waiting for the consultants report to be finalised.The results will be considered by the Diversity Manager/DDPO/Disability Forum and an action plan developed and published.

We will begin the preparations to undertake a benchmarking exercise against the Disability Standard.

The Diversity Manager will work with the Disability Forum Committee Members.

Diversity Manager/Disability Forum.

A representative of the Home Office shared their experiences of benchmarking against this standard at the Disability Forum AGM in November 2010.

We will issue guidance on disability matters for all staff

This will be completed by the end of November 2010.

Information Centre Manager.

All staff have access to the Employers Forum for Disability web site and advice line.Online leaflets providing a wide range of guidance on disability matters for staff and line managers are available via the intranet by the end of November 2010.