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									Workbook: Race Equality Impact Assessment

Copy and paste the policy that is being assessed:

Young Persons’ Housing Strategy

Stage 1:

Review Available Information

1.1 Reviewing the relevant information will enable you to assess the impact of the policy: • on different racial groups; and • whether there is potential for discrimination or • the policy fails to promote equality. Sources of possible data 1.2 The assessment may involve using:-

• Information that is already available on the Intranet or through relevant departments, for example:• Population Data – 2001 Census information can be found at:

• Inquiry reports - e.g. Climbie Report, Stephen Lawrence Inquiry Report. • Any previous reports, audits or monitoring of the policy.

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Workbook: Race Equality Impact Assessment

Q1. Outline the information that you have used to assess the impact of the policy:
The Race Relations Act 1976 & the Race Relations (Amendment) Act 2000 The Race Relations (Amendment) Act 2000 introduced a new positive duty to promote race equality, as well as amending the Race Relations Act 1976. It requires public authorities to have 'due regard to the need', in everything they do, to tackle racial discrimination, promote equality of opportunity, and to promote good relations between people from different racial groups. Under the Race Relations Act, it is unlawful for a person to discriminate on racial grounds against another. The Act defines racial grounds as including race, colour, nationality or ethnic or national origins. There are four main types of racial discrimination: direct, indirect, victimisation and harassment. The Act also gives the Commission for Racial Equality (CRE) the following duties: • • • • To work towards the elimination of discrimination and harassment; To promote equal opportunities and good relations between people from different racial groups; To review the Act, and make proposals for amending it, if necessary The Act also gives the CRE the power to issue codes of practice in the areas of employment and housing.

Commission for Racial Equality (CRE) The CRE is a publicly funded, non-governmental body originally set up under the Race Relations Act 1976 to tackle racial discrimination and promote equality of opportunity and good race relations. The CRE is governed by 15 commissioners, including a chair, who are responsible for making policy and providing strategic direction. The commissioners are appointed by the Home Secretary, and serve a four-year term. Code of Practice on Racial Equality in Housing The CRE first issued statutory housing codes of practice in 1991 (for rented housing) and 1992 (non-rented housing). In May 2005 it issued a new Code to replace both the 1991 and 1992 Codes. The aims were to: • Set standards for achieving racial equality; • Provide practical guidance that will help organisations and individuals involved in all areas of housing to avoid unlawful racial discrimination and harassment, promote equal opportunities for all, and encourage good race relations; and • Make sure that anyone who is considering taking a legal case, or who has concerns about the way decisions on housing matters have been made, understands the legislation, their rights, and what constitutes good practice in the field of housing. The Code also noted that:

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Workbook: Race Equality Impact Assessment

• • •

Black & Ethnic Minority (BME) households are more likely to live in overcrowded conditions, be more dissatisfied with their homes and be more anxious to move, compared with households from white groups (The Survey of English Housing 2005 confirms these findings) BME communities are up to three times more likely to be represented in statistics on homelessness. Segratation, mainly in urban areas where one ethnic group predominates over others, continues to pose problems for social integration in parts of the country. Racial harassment is a continuing reality for BME communities in some areas; for example, they are four times more likely to see racial harassment as a serious problem in their areas than white households.

Supporting People The Government’s advice on the ‘Supporting People’ initiative also noted that: The ethnic minority population of Britain, taken as a whole, has a much younger age structure than the white British population. However there are substantial differences in age structure between specific minority groups. The Pakistani and Bangladeshi populations have a large proportion under 16, 45 and 46 per cent respectively. The age structure of the African Caribbean population is more similar to that of white British people, with comparable numbers in each age group before retirement age. Nearly a fifth of the white population are over retirement age compared to less than on in 20 of the ethnic minority population as a whole. These age distributions reflect length of settlement. Since most migrants are young on arrival, those that are now old are from the groups longest established in Britain. Census 2001 In terms of the BME population in Milton Keynes, the table below shows that the BME population is a young population. 13.8% of the 16 – 24 year old population were from BME groups. This was higher than the percentage of ethnic minority groups amongst the whole population (13.2%).
Table xx: Age by size of ethnic groups and percentage of age population All White White White Mixed Asian or British Irish Other Asian British All 207,076 179,694 2,918 5,240 3,716 7,571 People 86.8% 1.4% 2.5% 1.8% 3.6% 16 – 24 23,326 20,097 170 532 536 1,039 86.2% 0.7% 2.3% 2.3% 4.5% Black or Black British 4,968 2.4% 610 2.6% Other

2,932 1.4% 342 1.5%

The Pupil Level Annual School Census (PLASC) The Pupil Level Annual School Census 2006 (PLASC) gives an insight into the current BME young person population, as it is an annual record of pupils in all levels of education.
Table xx: Minority Ethnic Groups Pupils in Milton Keynes Sixth Form Education National Approx. Age White British Ethnic Unclassified Number of Curriculum Minority Pupils

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Workbook: Race Equality Impact Assessment
Year Year 12 Year 13 Year 14 % 72.1 76.8 83.3 % 24.5 21.1 16.7 % 3.4 2.0 0

16 17 18

1,412 925 48

According to the table above there were higher percentages of BME pupils in Years 12,13 and 14 in January 2006 than in 2001. This suggests that the young person BME population has increased in recent years. The Milton Keynes Housing Needs Study 2006 contained useful information about the housing needs of BME Communities. This showed that in Milton Keynes: • • • • • • • • • • • • • 19.4% of households interviewed for Housing Needs Study were from a minority ethnic community; 23.6% of the respondents from BME households were under 25 years old, which was more than the proportion of under 25 years in all households (15.3%); 53.2% of ethnic minority households were earning £20,000 or less a year (compared to 46.9% of all households earning the same annual income); There was a higher proportion of under 25 year olds (23.6%) and 25 to 44 year olds (52.9%) in BME households than in all households (15.3% and 48.1% respectively); Only 0.9% of respondents BME communities were aged over 75 years (compared to 3.5% of all households); There was a slightly higher percentage of ethnic minority households (15.1%) in receipt of Housing Benefit compared to all households (13.2%); 31.3% of BME households owned with a mortgage; 30.3% rented privately; 12.5% owned outright; 11.6% rented from the Council; 7.3% rented from a Housing Association and 6.2% had a shared ownership property. Over twice as many BME households rented privately when compared to all households. 36.4% of BME households felt that their property was of appropriate size, this compares to 27% of all households; 9.4% of BME households felt that their properties had at least one bedroom too few, this compares to only 4% of all households; 43.3% of ethnic minority households felt that their property was unsuitable, this compares to 11.7% of all households. 30.1% of BME households felt their properties were overcrowded, which compares to only 4% of all households. 85.2% of BME households had no health problems in the households, this compares to 79.1% of all households.

Homelessness amongst young Black & Minority Ethnic Communities (BME) Between April 2004 and December 2005, 12.3% of homeless acceptances from 16 – 24 years olds were from BME groups. The percentage of young homeless BME people is broadly similar to the rest of the 16 to 24 years age population in 2001. However 37.2% of the total homeless acceptances were from an ethnic minority applicant aged between 25 and 34 years. This was a significantly larger percentage of homeless acceptances than the 16 – 24 years olds. Page 4 of 9

Workbook: Race Equality Impact Assessment

Reasons for homelessness amongst young ethnic minority people The main reason for homelessness amongst young BME people was “Friends no longer willing to accommodate” with “Parents no longer willing to accommodate” and ‘Termination of Assured Shorthold Tenancy’. This varied from the young white people, as ‘Parents no longer willing to accommodate’ was by far the most common reason for homelessness. Table xx below shows that 23% of the 16 – 24 year old Supporting People clients were from an ethnic minority background. This was higher than the total percentage of BME communities shown in the Census 2001 (13.2%) but more in line with the percentage of BME pupils in the latest PLASC data (22.9%). A more significant result is that the percentage of Black or Black British 16-24 year olds Supporting People clients was 13.5%. This was four times higher than the percentage of Black or Black British population in the Census 2001.
Table xx: Ethnicity of 16-24 year olds Supporting People clients between April 2003 – March 2005 No. of Supporting People Percentage of Supporting People Ethnicity Clients Clients White British 638 76.4 Black or Black British 113 13.5 Mixed 40 4.8 Asian or Asian British 21 2.5 White Other 12 1.4 Other 4 0.5 Refused 4 0.5 White Irish 3 0.4

The current statistics for young (16yrs to 24yrs) BME people suggest that: • There is a growing young person BME population; • 12.3% of young homeless acceptances were from BME communities, which were broadly similar to the young BME population. Also 37.2% of the homeless acceptances for the 25yrs to 34yrs were from BME communities. This was double the amount of 25yrs to 34yrs olds in the total population. • Black or Black British 16-24 yr old are over-represented in Supporting People client records.

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Workbook: Race Equality Impact Assessment Stage 2: Consult

2.1 Milton Keynes Council already consults people in a number of different ways. However, we will raise public confidence in our services if we use clear consultation methods (see Appendix A). 2.2 Internal consultation should focus on those staff who deliver the policy, particularly front-line staff. It is strongly recommended that policy developers consult at practitioner level to find out the true effect of the policy “on the ground”. 2.3 If, as a result of the review, there has been significant change to the policy it may be necessary to conduct further consultation. This is because any revised policy following the consultation is likely to be substantially different than that originally consulted on. Q2. Outline how you have consulted to assess the impact of this Policy: a) How the consultation was carried out
There were two stages to the consultation process; the initial information gathering stage and the consultation on the draft strategy. The initial information gathering stage included face-to-face interviews with services that work with young people as well as focus groups with young people, which led to the Draft Young Person Housing Strategy. This included agencies and organisations that work with young BME people. Examples include the Connexions worker based at the Unity Cyber Centre, young BME people who live independently in Milton Keynes, the BME Elders Forum and a Housing Survey that went out to the MK Hindu Association. The consultation on the draft involved sending a copy of the draft strategy to everyone that was involved in the initial information gathering consultation and completing a questionnaire with any additional comments. The consultation also included attending groups like the Equalities Consultative Committee, Youth Housing Network, Supporting People Forum and providing a presentation on the draft strategy followed by a sessions for feedback on the strategy. Finally focus groups were held with young people living independently and young people in 6th forms and MK College, which included young BME people.

b) A summary of the responses
In the consultation there were no specific issues highlighted for BME young people. Response to the initial information gathering consultation included:

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Workbook: Race Equality Impact Assessment
• • • • • • • • • • • • • Affordability More Supported Housing Issues with maintaining tenancies Issues with young people who have complex needs Unsuitable housing Lack of available housing for young people Lack of partnership working between agencies and organisations Homelessness Lack of information about housing for young people Need for education and training for young people about living independently. Lack of security People don’t listen to young people’s problems Lack of life skills.

Responses to the consultation on the draft strategy were recorded and amendments were made accordingly.

c) What you propose to do as a result of the consultation
Response to the initial consultation has developed the draft strategy. Responses to the consultation on the draft strategy were recorded and amendments were made to the strategy accordingly.

Stage 3:

Consider and make changes

3.1 If the policy does discriminate against certain groups, there are a number of options:• Adapt Can the policy be adapted to eliminate any adverse effects? • Alternative means If the assessment or consultation reveals that certain groups have different needs, can you meet those needs, either within the proposed policy or in some other way? If the policy is indirectly discriminatory, can you find another way of meeting the Service’s aims, which will not impact adversely on a particular group? • Abandon Does the policy need to abandoned because the policy is indirectly discriminatory and cannot be justified.

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Workbook: Race Equality Impact Assessment

Q3. Does the information or consultation indicate that the Policy has a differential impact on particular racial groups? (if yes, go to question 4, if no, go to question 8)
No. However it is worth noting that whilst homelessness amongst young BME people is equal to their representation in the Milton Keynes population, BME people aged between 25 and 34 years were over-represented in the homeless statistics. Also, the statistics for the Milton Keynes Supporting People clients showed that Black or Black British clients were over represented in the client records.

Q4. Which racial groups are affected?

Q5. Is the differential impact an adverse one for those racial groups i.e. does it put those racial groups at a disadvantage?

Q6. Is there evidence that this Policy: a) Is discriminatory or perceived as discriminatory? No b) Is damaging good race/ failing to promote good community relations? No

Q7. If the Policy adversely affects people from certain racial groups, can it be justified because of its overall objectives? (Direct discrimination is not, in law, capable of justification; only indirect discrimination can be objectively justified)

Q8. What changes, if any, have you made to the Policy as a result of the Race Equality Impact Assessment?
Inclusion of statistics on homelessness for young BME people and Supporting People clients.

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Workbook: Race Equality Impact Assessment Stage 4: Monitoring

4.1 In order to identify the affect of a policy it is essential to have an effective system. Monitoring is the most reliable way of knowing whether a policy is effective and ensuring that it is not discriminating against certain groups. 4.2 The monitoring process scrutinises and examines the actual impact of a policy. It should indicate whether and how well the policy is achieving its aims and indicate opportunities for improvement. 4.3 Monitoring allows you to test:-

• Compliance with the policy • Levels of satisfaction with the policy • How particular groups are affected by the policy

4.4 The amount of time and effort spent on monitoring should be proportionate to the impact of the policy. For example, priority should be given to monitoring the effect of those policies that affect different groups in different ways. 4.5 You can use a range of methods to monitor and analyse the effects of the policy on different groups, including: • Statistical analysis e.g. usage of service • Random or targeted surveys • Meetings, focus groups, citizens’ juries, Employment Tribunals, compliments/complaints; and • Satisfaction surveys. Q9. State how the on-going effects of this Policy will be monitored, and who will be responsible for this monitoring.
The on-going effects of this Policy will be monitored as part of the monitoring of the Action Plan in the Young Person Housing Strategy, which will be monitored by the Local Housing Strategic Partnership.

Q10. When is it planned to review this Policy next?

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