Initial Equality Impact Assessment
An Equality Impact Assessment is an examination of a proposed function, strategy, procedure, practice, project, or decision to see if it could adversely affect those with protected characteristics.
Policy aims and outcomes
Give a brief summary of the aims, purpose and outcomes of the policy / procedure.
What is this policy intending to achieve?
- Improve fairness and transparency in HRA Community payments
- Manage legal and regulatory risk
How does it intend to achieve this?
- Clarifying of roles and activities by including a directory of activity types, describing what’s included in each, whether they attract payments and if so, how
- Checklist of information that should be included in activity descriptions
- Clear process so staff can take a consistent approach – with appropriate flexibility to achieve strategic aims
Who is it intended to benefit, and how?
- HRA Community members – by improving fairness and transparency
- HRA staff – by clarifying decision-making and payment processes
- Executive Committee – by providing assurance that our approach is an appropriate use of public money and management of risk
Are there any disbenefits for staff, the HRA community, stakeholders, the public?
- It’s an additional policy in a crowded policy-scape.
- Staff with an already high workload may need to process additional payments for REC and CAG members.
- Staff leading activities may need to take additional steps (completion of an activity description and CEST form) before involving Community members in their work.
- Some Community members may receive payments through more than one process. This may increase the administrative burden for some Community members.
- Some stakeholders may decide to follow suit and introduce identity checks for similar roles, increasing the administrative burden on staff and members of the public.
- In future, some advisory or decision-making roles may require identity checks. Individuals without photo ID, or without a smart phone, may experience more barriers completing these checks.
Assessment Questions to determine relevance and impact
1. Could the policy / procedure result in a positive impact upon the Public Sector Equality Duties to:
- eliminate unlawful discrimination (Yes)
- promote equality of opportunity (Yes)
- foster good relations between people who share a protected characteristic and those who do not (Yes)
If you have answered YES to any of the questions in 1. above, please explain the impact you have identified.
At present, REC and CAG members are involved in activities alongside public contributors where the former are not offered payments and the latter are. This feels unfair.
By offering payments to all Community members who are using their experience and insight to inform and shape our work, a wider range of people may be able to get involved.
The HRA Community demographic report may be a useful reference point.
Whilst the data is not split between REC, CAG and public contributors, there may be perceptions around protected characteristics of different groups e.g. age, disability, ethnicity.
2023 demographic data for our community.
There was a 67% response rate to a demographic data survey. 592 responses were received from REC members, 33 from public contributors and 16 from CAG members.
The conclusions below are taken from the demographic report: HRA Community demographic report - Health Research Authority
Comparing the data collected to ONS data, we noted:
- Age: the HRA Community is an older population, which is out of proportion with the English and Welsh population. While 60% of our members are aged 60+, we have no members under the age of 20, and few aged 20-29.
- Disability, chronic health conditions and neurodivergence: Around 9% of our members consider themselves to be disabled, which is lower than the English and Welsh population. However, about 32% reported having a chronic health condition, and 7% considered themselves neurodivergent e.g. being dyslexic, dyspraxic, autistic, or having attention deficit hyperactivity disorder (ADHD). This tells us that a substantial proportion of our community may benefit from accessibility considerations, whether or not they see themselves as disabled.
- Ethnicity: Black / African / Caribbean / Black British people are underrepresented within our member groups, while all other ethnicities are broadly in line with the English and Welsh population.
- Gender: HRA membership has a higher proportion of women (58%). The majority of our members (99%) reported that their gender identity was the same as their sex as recorded at birth, which is slightly higher than the English and Welsh population based on the census (94%).
- Religion or belief: A significant proportion of our membership are Christian (40%) or have no religion (35%). This is broadly in line with the English and Welsh population. Muslim people are underrepresented in our membership.
- Sexual orientation: The majority of HRA membership (85%) identifies as heterosexual, which is slightly lower than the English and Welsh population. A notably higher proportion of our membership (10%) identified as being LGB+ when compared with the English and Welsh population (3%).
- Carer status: Most of our members reported having no carer responsibilities (70%). Those who did report caring responsibilities were predominantly carers of a child or children (12%) with only small proportions caring for older people (6%), adults (2%) or disabled adults (2%).
- Employment: Nearly half of our members are employed either full or part-time (46%). A similar proportion (44%) are retired.
2. Could the policy / procedure result in an adverse impact upon the Public Sector Equality Duties to:
- eliminate unlawful discrimination (Yes)
- promote equality of opportunity (Yes)
- foster good relations between people who share a protected characteristic and those who do not (Yes)
If you have answered YES to any of the questions in 2. above, please explain the impact you have identified.
Offering payments to CAG / REC members for activities beyond their volunteer committee role
Some people may choose not to take up this offer due to the administrative burden or concern about how it may impact their financial situation. This may be more likely for people receiving welfare benefits, health insurance payments, maternity pay. Therefore, some people in these groups may be less likely to benefit from the change set out in the policy.
Receiving payments from the HRA through more than one method
This could create an additional administrative burden in terms of record keeping and declaring income to HMRC. It may impact people on a low income, disabled people and neurodivergent people more.
Future considerations in relation to ID checks (no change in policy at this time)
Asking people involved in our work to present documents that confirm their identity, could be more of a barrier for people without photographic ID such as a passport and/or driving license, people concerned about presenting this, and people who experience barriers accessing online systems that require a smart phone. This could include:
- older people
- young people
- disabled people
- members of the Gypsy, Roma and Traveller community
- trans and non-binary people
- people on a low income
- people who are unemployed
- people experiencing homelessness
- people who have changed their name (marital status)
Photographic ID Research - Headline Findings
Updated impact assessment of the draft legislation on people with protected characteristics - GOV.UK
Future considerations in relation to moving from BACS to payroll for some activities
This could create a barrier for people receiving universal credit, or an administrative burden for people who may need to liaise with HMRC to clarify tax codes etc. This may be more likely to impact on people not in full time employment and disabled people and neurodivergent people.
3. Could the policy / procedure result in a positive impact on some of our workforce (including our community), stakeholders or the public because they have one or more of the protected equality characteristics:
- Age (all and any age groups) (No)
- Disability (incl. mental, physical, sensory, long term health, neurodivergence) (No)
- Gender reassignment (thinking about transitioning, in the process of transitioning, or having transitioned, from one sex to another) (No)
- Marital/ Civil Partnership status (being married or civil partnered) (No)
- Pregnancy/ maternity (pregnant, on maternity leave or breastfeeding after a return to work) (No)
- Race (ethnicity, skin colour, current and original nationality, citizenship, ethnic or national origins) (No)
- Religion or belief (incl. people with no religion or belief) (No)
- Sex (male, female) (No)
- Sexual orientation (attracted to the same/opposite/both sex(es)) (No)
- Please also consider characteristics not explicitly covered: non-binary gender identities; diverse sexual orientations (e.g. asexual); socioeconomic status; caring responsibilities; parental leave for partners (No)
If you have answered yes to any of the protected characteristics above in question 3. please give further information about the potential positive impact, including any relevant data:
Whilst the new policy doesn’t have a direct positive impact on individual characteristics, the overall impact is to improve fairness and transparency in HRA Community payments which will benefit all members of whom this applies.
4. Could the policy / procedure result in an adverse impact on some of our workforce (including our community), stakeholders or the public because they have one or more of the protected equality characteristics:
- Age (all and any age groups) (Yes)
- Disability (incl. mental, physical, sensory, long term health, neurodivergence) (Yes)
- Gender reassignment (thinking about transitioning, in the process of transitioning, or having transitioned, from one sex to another) (Yes)
- Marital/ Civil Partnership status (being married or civil partnered) (Yes)
- Pregnancy/ maternity (pregnant, on maternity leave or breastfeeding after a return to work) (Yes)
- Race (ethnicity, skin colour, current and original nationality, citizenship, ethnic or national origins) (No)
- Religion or belief (incl. people with no religion or belief) (No)
- Sex (male, female) (No)
- Sexual orientation (attracted to the same/opposite/both sex(es) (No)
- Please also consider characteristics not explicitly covered: non-binary gender identities; diverse sexual orientations (e.g. asexual); socioeconomic status; caring responsibilities; parental leave for partners (Yes)
If you have answered yes to any of the protected characteristics above in question 4. please give further information about the potential adverse impact, including any relevant data:
Described above
5. Based on the responses above, please describe any actions that will be or have been taken to mitigate or minimise any negative impact for our workforce (including our community), stakeholders or the public, and to consolidate, communicate or build on any positive impact?
Clear communication with Community members who are impacted by the policy so they can understand the implications and decide if they would like to take up the offer of payment or not.
Signposting to HMRC helpline and benefits advice service.
If implemented for public contributors in future, support offered in completion of ID/RTW checks.
6. Give details of any consultation carried out related to the policy and / or the EIA
2025 07 Summary of information and feedback received from other organisations.docx
7. Give details of any changes to be made to the policy as a result of this analysis.
We have decided to proceed with offering payment to REC and CAG members for activities beyond their voluntary roles. When discussing with UKREDG, the group were keen to be kept up to date but did not express strong concerns.
We have decided not to introduce ID and RTW checks for all public involvement activities. At this point as this is not yet common practice across the sector.
To make it easier for people from underserved groups to get involved in shaping our work, in future we will consider offering vouchers as payment for one-off activities where people are sharing their experiences or perspectives with the HRA.
If you have answered YES to any of the questions in 2 and 4 above and the answers to question 5, 6 and 7 do not mitigate and adequately address the adverse impact, you may need to complete a full Equality Impact Assessment. Please consult the HRA Inclusion Manager for further advice.
Is a full Equality Impact Assessment required?