Emergency Housing Equality Impact Assessments
Making sure that equality and diversity adds value and improves outcomes.
The Equality Impact Assessment
1. Title: Emergency Housing, Temporary Accommodation and Home loss Policy
2. Scope: Review of Policy
3. Date of assessment: March 2024, then reassessed 25/07/24 following customer feedback
Amendment to title (removing word decant) following recommendations from HO 14/03/25
4. Name of person(s) carrying out stage one: Luke McCreery
Questions
1. Are there any particular groups who don’t or can’t access the service? - No
The policy sets out Curo’s approach to dealing with customers who need temporary or permanent moves due to regeneration activity, or planned or emergency works to their home that cannot be completed with them in occupation. It sets out what the compensation arrangements are for a range of scenarios.
2. Does your information suggest that some groups of people are more dissatisfied than others in this area? - No
The process is currently being reviewed now we have a resident liaison officer in post, with the aim of improving the service for customers and reducing overall costs.
3. Are there any issues relating to discrimination, harassment or victimisation that need to be addressed? - No
4. Are there any case law or human rights issues that need to be considered as part of this assessment? (see below*) - No
Case law may affect home loss regulations. Awaabs law may impact on the timeliness and the way in which we decant customers, particularly those with certain health needs
5. Could work in this area improve access to employment, learning or training? - No
6. Does this service provide opportunities to foster better relations between different groups of people? - No
7. Could there be any significant risks to the business if equality issues are not addressed? - No
8. If certain people are excluded from this service, do you need to provide rationale and justification for this? - Yes
This P&P applies to all customers with a tenancy. It will be implemented site by site, as and when the need arises. Operational managers will be required to consider all relevant information about affected customers for specific projects, the context of their location, and the degree of urgency required.
*The following Articles in the Human Rights 1998 may be relevant:
• The right to respect for private and family life
• Freedom of thought, conscience and religion, and freedom to express your beliefs
• Freedom of expression
• The right to marry and to start a family
• The right not to be discriminated against in respect of these rights and freedoms
• The right to peaceful enjoyment of your property
• The right to an education
The EIA focuses on assessing whether the service may have a different impact (negative and positive) on different groups of people and whether there are opportunities for positively promoting equality. It will also help identify actions which can be taken or reduce or remove negative impact and promote equality.
5. What do you already know from employee or customer opinion about the service?
Give details of customer feedback, any research, consultation or data that has been collected.
Voicebox customers have reviewed the proposed policy and feedback:
• Very clearly written
• Very easy to read
• Clear and Concise use of language
• Just the right length (any longer to boring, any shorter and not enough detail)
• No issues relating to disabilities not being considered by the policy
6. What are the issues for different equality groups?
At the heart of the process is responding to individual need and ensuring we make changes that improve access and remove barriers for all including those with multiple challenges and complicated lives.
Equality Group/Protected Characteristics - Issues
Gender - There is no anticipated impact as a result of this policy.
Different Religion or Beliefs - There may occasionally be circumstances where customers need us to take account of the location of places of worship when allocating properties – this is reflected in the decant checklist. Colleague Experience Team 7
We should also consider community networks where possible.
Likewise, if there are specific property types or layouts required this can be agreed with the customer and provision made where it is reasonably possible.
Age – including older and younger people - The policy and supporting procedures ensure what additional support customers who are vulnerable, including vulnerability by means of age, may be required to ensure appropriate solutions are identified and moves supported. The policy also makes provision to replicate any special adaptations that a customer has the use of, in their new home. In certain circumstances, where customers are moving to a new home or having adaptation work completed there may be a positive effect as customers may be better able to maintain their independence in a new or adapted home.
The policy ensures those in vulnerable groups are protected and decisions can be taken to decant where we would not ordinarily do so based on age (elderly for example, and damp issues).
The policy also ensures we will do our best to ensure children are re-housed near to their school to minimise disruption to their daily routine.
Disability - Including: sensory, physical, learning disability and mental health - The policy and supporting procedures ensure what additional support customers who are disabled or who have a long-term limiting illness, may require ensuring appropriate solutions are identified and moves supported. The policy also makes provision to replicate any special adaptations that a customer has the use of, in their new home. In certain circumstances, where customers are moving to a new home or having adaptation work completed there may be a positive effect as customers may be better able to maintain their independence in a new or adapted home.
In some cases, a decant is not deemed necessary by our repairs teams, however the specific needs of the resident, for example mental health, may mean a decant is considered outside of the scope of the policy. This decision will be made by the director of the relevant repairs team and resident liaison officer, but supporting documentation may be required.
People from different ethnic backgrounds - The policy and supporting procedures ensure that if a customer has specific housing or support needs (an example in this case could be translation services) that these are identified when the decant is planned and agreed with the customer.
Sexual Orientation - The policy and supporting procedures ensure that if a customer has specific housing or support needs that these are identified when the decant is planned and agreed with the customer. We will ensure that customers are housed where possible in communities that will support and not discriminate.
Pregnancy, Maternity and Paternity - The policy and supporting procedures ensure that if a customer is pregnant or has specific access or location requirements that these are considered when allocating a decant property/new permanent home.
In certain circumstances, where customers are moving to a new/permanent home there may be a positive effect as customers may be allocated additional space for the unborn child/baby.
Trans-gender - The policy and supporting procedures ensure that if a customer has specific housing or support needs that these are identified when the decant is planned and agreed with the customer.
Marriage & Civil Partnerships - There is no anticipated impact as a result of this policy.
Community relations and cohesion - None
Human Rights - None
Any other issues:
Caring responsibilities - The policy and supporting procedures ensure that if a customer has specific housing or support needs that these are identified when the decant is planned and agreed with the customer.
There may be circumstances where a carers situation is improved, if they live in the same property as the person being cared for, if the decant property better meets the needs of the person being cared for – for example a better layout, more space or adaptations.
Rural isolation - It can be challenging to decant customers in rural communities, where the housing supply is more limited. We adhere to local authorities’ Rural Exception Criteria, any Section 106 Criteria and local lettings plans.
The supporting procedures ensure that colleagues take account of transport issues that may affect customers, and the policy ensures customers are reimbursed any additional travel costs associated with work or education whilst in any temporary accommodation.
Socio-economic - The policy sets out how customers will be reimbursed for out of pocket expenses. The policy allows for interim payments to be made to customers that require this.
Where possible we use our own contractors for services (for example cooker disconnection and re-connection) reducing the amount of “out of pocket” expenses customers need to claim.
7. What are you going to do to address the issues mentioned above?
N/A
8. Describe how you are going to make sure that the relevant people know about the changes you are making and the actions you have agreed in this EIA.
- Publish with policy on Orb
- Team meetings
- We use external services to provide homes under this policy and we review with them our assessment and requirements in relation to equalities in implementing those procedures. For example we notify hotels of specific needs when moving vulnerable customers into their accommodation.
9. Give details of how you will monitor the impact of the changes you are making.
- Policy updates and review
- Reviews of procedures
10. Signing off the Impact Assessment
The function/policy has been fully assessed in relation to its potential effects on equality and all the relevant concerns have been addressed.
Name: Luke McCreery
Job Title: Director of Property Maintenance
Date: 09/04/2025