Equality Impact Assessment for COVID-19 secure working practices
Equality Impact Assessment
|Assessment of:||COVID-19 – reopening to the public|
|Service:||Libraries Unlimited/Devon Libraries|
|Version:||Version 2 – 18.12.2020|
|Assessment carried out by (incl. job title):||Emily Macaulay – Service Delivery Manager for Exeter, Teignbridge and East Devon|
Section 1 – Background
|Description:||Libraries Unlimited runs Devon County Council’s and Torbay County Council’s public library services – which includes 54 libraries across the county and 4 mobile libraries. We also have a Home Library Service, where deliveries are made by volunteers. We have around 360 staff across the county, in permanent and variable hours roles. We have approximately 250,000 visits per month across our libraries in a normal month, and hold around 1100 events.|
From 6th July 2020 onwards, we gradually reopened the libraries to the public, with almost all of our libraries now reopen to the public. Mobile Libraries are also now allowing limited customers to board, and we also started to welcome volunteers back into libraries from the beginning of October. Staff who were advised to shield earlier in the year have now been allowed to return to work, although we continue to support vulnerable staff to work from home wherever that is possible, but unfortunately that is not an option for most staff who are needed in library buildings to serve customers. If staff are unwell with COVID-19, then they will be paid sick pay as normal; if they are not unwell, but have been asked to self-isolate (because a member of their household has shown symptoms or they have been told to self-isolate by Test & Trace, or they have symptoms but feel well enough to work), then we will consider on an individual basis any work that they may be able to do from home, which could include completing online training, preparing for an event or updating social media. The work they do from home may not be their normal work, and could be project work for another team or library, and full training/support will be provided in that situation. Staff in this circumstance will be encouraged to complete the skills audit and will be paired up with other teams as appropriate. Where staff in these situations do not have access to IT equipment, they will be prioritised for any equipment that is available. Where it is absolutely impossible for someone in these groups to work from home due to lack of internet or any tasks, or there is not enough they can do from home to fill all of their normal working hours, then we appreciate how important it is to self-isolate to protect both themselves and colleagues and customers, many of whom are vulnerable, then sick pay under their normal contractual guidelines will be agreed. Staff will need to make sure that they are making every effort to get a coronavirus test as quickly as possible, and they can return to work as soon as they get a negative result.
From the beginning of August, all customers legally have to wear a face covering in the library (unless they are exempt). From the beginning of October, all library staff also have to wear face coverings as well (not visors) and this will be legally required in public areas of the library.
Schools have now reopened, but some schools have been introducing temporary closures or sending home year groups or classes where someone in that “bubble” has tested positive. If a member of staff needs to take time off to look after a child because of an individual school closure, or they need to care for someone else but have not been asked to self-isolate themselves, the normal Time Off for Dependents policies will apply, so this leave will be holiday or unpaid leave.
Section 2 – Key impacts and recommendations
|Social/equality impacts:||As detailed below|
|Environmental impacts:||As detailed below|
|Economic impacts:||As detailed below|
|Other impacts (partner agencies, services, DCC policies, possible ‘unintended consequences’):||The contents of this document will be available for all Libraries Unlimited staff to view. It will also be available to:|
· Devon County Council and Torbay Council as Commissioners
· Libraries Unlimited’s Board of Trustees
· Unison, GMB and other trade unions as appropriate
|How will impacts and actions be monitored?||This is a living document and we will regularly review this Impact Assessment throughout the progress of the disease and update it following feedback from staff where appropriate.|
Section 3 – Profile and views of stakeholders and people directly affected
|People affected:||Staff who work across all our libraries|
|Diversity profile and needs assessment of affected people:||Data correct as of 14 December 2020:|
80% of our staff are female and 20% of our staff are male.
We have made a big effort to collect information on other protected characteristics as this information did not transfer from DCC nor Torbay Council, and we now hold information for around 96% of our staff.
20% have told us that they are the primary carer for a child under 18 years old. 3.7% of people have told us they are the primary carer for an older person, 1.1% are the primary carer of a disabled adult and 4% are the secondary carer for a child under 18 years old.
70.2% of staff have told us they are heterosexual; 4% have told us they are bisexual; 0.6% have told us they are a Gay Man; and 0.3% that they are a Gay Woman/Lesbian. 20.7% have said they would prefer not to say in response to this question. We are not aware of anyone who is transgender, or who now has a different gender from their birth.
3.7% of staff have told us they have a disability
The high majority of our staff are White English or from another White background (over 95%).
The biggest groups for staff who have told us their religion/belief are Christian (35.8%) and No Religion and Belief (42%). Other religions are Buddhist and Other Religion/Belief. 13.6% have said that they would prefer not to say in response to this question.
67% of staff have told us they are married, co-habiting or have a partner.
The age profile of our staff is (yrs):
84.8% of our assignments are less than 37 hours per week.
|Other stakeholders:||· Devon County Council and Torbay Council as Commissioners|
· Libraries Unlimited’s Board of Trustees
· Staff Forum and Trade Unions
|Research and information used:||Payroll and other HR data|
Latest guidance from the government, Public Health England and NHS England
· Staff Forum
· Workforce, Resources and Remuneration Committee
· Board of Trustees
· Leadership team
This section describes how relevant questions and issues have been explored during the options appraisal.
Section 4a – Social Impacts
Giving Due Regard to Equality and Human Rights
You must consider how people will be affected by the service, policy or practice. In so doing we must give due regard to the need to:
- Eliminate unlawful discrimination, harassment and victimisation
- Advance equality of opportunity and
- Foster good relations
Where relevant, we must take into account the protected characteristics of age, disability, gender, gender reassignment, pregnancy and maternity, marriage and civil partnership, sexual orientation, race, and religion and belief.
This means considering how people with different needs get the different services they require and are not disadvantaged, and facilities are available to them on an equal basis in order to meet their needs; advancing equality of opportunity by recognising the disadvantages to which protected groups are subject and considering how they can be overcome.
We also need to ensure that human rights are protected. In particular, that people have:
- A reasonable level of choice in where and how they live their life and interact with others (this is an aspect of the human right to ‘private and family life’).
- An appropriate level of care which results in dignity and respect (the protection to a private and family life, protection from torture and the freedom of thought, belief and religion within the Human Rights Act and elimination of discrimination and the promotion of good relations under the Equality Act 2010).
- A right to life (ensuring that nothing we do results in unlawful or unnecessary/avoidable death).
The Equality Act 2010 and other relevant legislation does not prevent the Council from taking difficult decisions which result in service reductions or closures for example, it does however require the Council to ensure that such decisions are:
- Informed and properly considered with a rigorous, conscious approach and open mind, taking due regard of the effects on the protected characteristics and the general duty to eliminate discrimination, advance equality and foster good relations.
- Proportionate (negative impacts are proportionate to the aims of the policy decision)
- Reasonable, and
- Those affected have been adequately consulted.
|Characteristics||Describe any needs and actual or potential negative consequences (e.g. disadvantage or community tensions) for the groups listed.|
(Consider how to mitigate against these).
|Describe any needs and actual or potential neutral or positive outcomes for the groups listed.|
(Consider how to advance equality/reduce inequalities as far as possible).
|50% of our workforce is aged who are over the age of 50. The evidence is that older people are more at risk from COVID-19, as they have a greater chance of complications, because as our bodies’ age, our immune system becomes weakened. COVID-19 seems to have the biggest impact on those people who are over 80 years old. However, there are higher percentages in the 71-80 age bracket and the 61-70 bracket, and those over 70 have been defined as clinically more vulnerable and advised to rigorously follow the social distancing guidelines. Older staff may also have a higher risk of having underlying health conditions.|
Mitigation – We have a 2.6% of our workforce aged over 70 years old. The current guidance from the government does not recommend that older people self-isolate or not return to work (unless they have any symptoms, live in a household where someone has symptoms or have been told to do so by Test & Trace ), but they have been advised to rigorously follow the social distancing guidance. We will ensure that all staff can maintain a 2m distance from their colleagues at all times so this will also apply to those people over 70 anyway, and multiple personal face coverings have also been provided. Line managers had conversations with their teams, following guidance provided by HR, about their individual circumstances (in July and in October) and those in the clinically vulnerable group have been offered the option of the safest available on -site roles, enabling them to stay 2m away from others. If due to the nature of their role, they can continue to work from home then they should be supported to do so.
|There is some evidence that over 65 year olds are less likely to have internet access at home than younger age groups, although this is increasing. Therefore it may be easier for some staff who have struggled to work from home to return to working in library buildings.|
|Age (cont’):||There is some evidence that over 65 year olds are less likely to have internet access at home than younger age groups, although this is increasing. This may make it harder for older staff to work from home, and also to book a coronavirus test quickly as people are advised to do this online.|
Mitigation – with the buildings reopened to the public, staff will be supported to work from the library building again and adjustments to normal working practices and risk assessments will be put in place to ensure that social distancing can be rigorously observed, so staff should not need to continue to work from home in most cases. Where they have symptoms/have a household member with symptoms/have been contacted by Test & Trace but feel well enough to work from home, their manager should support them to be able to follow the guidance and provide them with tasks so that they can work from home. If they do not have suitable IT equipment or connectivity at home, they should be prioritised for any equipment that is available (please speak with IT about this), or given tasks that do not require Internet access if that is possible. In circumstances where it is absolutely impossible for the above groups who have been told to self -isolate to work from home and all these options have been explored, then they will be entitled to the sick pay they would be entitled to if it was a normal sickness absence. If someone is unable to book a coronavirus test online, then they can contact 119 to book a test by phone. Their line manager can also offer to support them in booking a test online if they feel comfortable doing that.
|Disability (incl. sensory, mobility, mental health, learning disability, ill health) and carers of disabled people:||Those with pre-existing health conditions are potentially at greater risk from COVID-19.|
Mitigation – where health conditions are known, additional guidance will be shared with staff from PHE or from relevant support charities (e.g. Asthma UK). They will then be supported at work and to rigorously follow the social distancing, along with those who are clinically more vulnerable but who have not been advised to shield – all these staff will be offered the option of the safest available on-site roles, enabling them to stay 2m away from others. If due to the nature of their role, they can continue to work from home then they should be supported to do so. Frontline staff have also been provided with multiple personal face coverings which they are legally required to wear in all public areas, and handwashing and hand sanitisers stations will be available. Customers will also be legally expected to wear a face covering, which should minimise the risk of infection from them as well. Full risk assessments have been carried out of each location and individual mitigations put in place where required.
|There is a possibility that this proposal could have a positive impact on staff with poor mental health who have found isolation and lack of their normal routine challenging to be able to return to socially distanced contact with colleagues/customers and to a more normal structure.|
|Disability (incl. sensory, mobility, mental health, learning disability, ill health) and carers of disabled people (continued):||Those with pre-existing health conditions may already have higher sickness levels, so may hit trigger points/not meet targets/have used all or some of their sick pay entitlement if they have to take sick leave as a result of COVID -19.|
Mitigation – all absences are considered on a case by case basis, and if absence levels have shown an improvement apart from absences related to COVID -19, then this will be taken into account. If they have no entitlement to company sick pay remaining, we would then discuss with them how this could be managed. This could include spreading any pay/deductions over several months including after they return to work, using holiday to offset any unpaid sickness, or considering a limited amount of work that they could do from home which would enable them to still be paid for a proportion of their working time.
|Disability (incl. sensory, mobility, mental health, learning disability, ill health) and carers of disabled people (continued):||Staff who are carers of people with disabilities may need to take time off work to care for them if they are diagnosed with COVID -19 or have been advised to self isolate. This would include secondary carers having to manage their time to support dependents. Some of the need for time off work / to work flexibly may be at short notice if other care arrangements are affected.|
Mitigation –Parental Leave and Time Off for Dependents policies are in place which allow for staff to take time off in these situations. In the case of serious illness, the Compassionate Leave, which allows for some paid leave, may be relevant. The provisions under Parental Leave and Time Off for Dependents are unpaid, but it may be possible for some staff to continue to work from home, which will be considered on a case by case basis. Where unpaid leave is taken, all options will be considered with them to mitigate the impact of this. This could include spreading any pay/deductions over several months including after they return to work, using holiday to offset any unpaid sickness, or considering a limited amount of work that they could do from home which would enable them to still be paid for a proportion of their working time.
|Disability (incl. sensory, mobility, mental health, learning disability, ill health) and carers of disabled people (continued):||The change of Government Guidance in relation to face coverings now means all staff will be wearing masks that cover their mouths entirely, when interacting with customers. This will make it harder for people with some disabilities, such as those with hearing impediments who rely on lip reading; to communicate. In addition any staff with existing breathing difficulties who may struggle to have their breathing restricted even minimally by wearing a mask.|
Mitigation – it is now a legal requirement for staff and customers to wear face coverings in the libraries, so we have no flexibility as an organisation on whether or not we implement it. However, one of the exemptions is if you are speaking to or providing assistance to someone who relies on lip reading, clear sound or facial expressions to communicate so this should be considered on an individual basis by Library Supervisors about how to accommodate this whilst also maintaining safety.
|Some staff will also be exempt from wearing a face covering under the legislation because they cannot put on, wear or remove a face covering because of a physical or mental illness or impairment, or disability, and we will therefore support all staff in that situation once we have that confirmation from them. Staff have the option to wear a badge or other identifier that explains they are exempt to minimise questions from customers and colleagues; or allowing them to refer all such questions to the Library Supervisor. Staff can request a badge from HR. All staff have also been provided with a visor as well, which whilst it does not count as a face covering, may be something that people who are exempt from wearing a face covering choose to wear instead. We will also be ensuring that 2m social distancing can be maintained at all times as well, regardless of whether someone is wearing a mask/visor or not. Where staff wearing masks need additional tools to communicate with individuals that are struggling to hear they can look to utilise a speech -to -text function such as Google Translate which can be installed as an app on most mobile phones.|
|People with some skin conditions may find that wearing items such as gloves or masks causes problems for their skin, and also regular handwashing may also irritate existing conditions.|
Mitigation – although there is now a legal requirement for staff to wear face coverings in public areas of the library, staff who cannot put on, wear or remove a face covering because of a physical or mental illness or impairment, or disability are exempt under the legislation. Line managers will have regular conversations with their teams to discuss any issues that they may have, and we will endeavour to provide equipment that is better suited to their needs as appropriate (such as visors which do not touch their face, gloves made of different materials if required, hand sanitiser as this can be less of an irritant ). Guidance will also be sourced from appropriate organisations and provided to staff, and we will also consider any reasonable
|There is a lot of written communication being circulated, some of which could be quite long and complex. Due to the nature of some disabilities, such as dyslexia, this may be more difficult for some staff to digest and understand.|
Mitigation – every effort will be made with the documentation to ensure that it is in easy to read English, avoiding complex wording, acronyms and jargon as much as possible. Where staff are finding it more difficult, then they will be encouraged to discuss with their line manager, who will be able to provide additional support and answer any questions. In the case of individual staff where there may be challenges to them fully engaging, this will be discussed with the individual staff to ensure that their needs are met. It may be appropriate for their line manager to arrange some time to go through the guidance with them, and some staff will already have adjustments or equipment in place to help them with managing the documentation. Additional time will be given during their normal working hours as well to ensure that they have time to read anything if that takes longer.
|There is a possibility that working in the libraries could have a negative impact on staff with poor mental health, and potentially cause stress and anxiety if they are worried about increased contact with the public in library buildings. Worry or concerns about dealing with members of the public who ignore or challenge the rules could also affect people’s mental health.|
Mitigation –Line managers will be having regular conversations with their teams to listen to and address any concerns. Occupational Health and the Employee Assistance Programme are available to all staff, as well as signposting to additional services – a wide range of additional resources are available on SharePoint that some staff may find useful. Our risk assessments and communications will aim to reassure staff who are concerned about the measures that are in place to keep them safe, both from risk of infection and potentially angry customers, and we will take onboard feedback/any requests to adapt processes to increase individual’s safety.
|Culture and ethnicity: nationality/national origin, skin colour, religion and belief:||There has been some evidence that those from Black, Bangladeshi and Pakistani backgrounds are more likely to develop and to die from COVID -19 than white populations. The reasons for this are not currently absolutely clear.|
Mitigation – we have a very small number of staff who have made us aware that they fall into this category (0.27%). Our aim is to ensure that all staff are protected as much as possible from the risk of infection, by ensuring they can maintain 2m social distancing, providing masks and visors, and the other detailed guidance that has been put in place. We will continue to monitor the evidence and guidance on this, and update any procedures/risk assessments as required. As with all other staff, line managers will be having conversations with all BAME members of their team to discuss any concerns that they have, and also to discuss any underlying health conditions that may put them at greater risk.
|Culture and ethnicity: nationality/national origin, skin colour, religion and belief (continued):||There is a lot of written communication being circulated, some of which could be quite long and complex. Those who are second language speakers may find this more difficult to digest and understand.|
Mitigation – every effort will be made with the documentation to ensure that it is in easy to read English, avoiding complex wording, acronyms and jargon as much as possible. Where staff are finding it more difficult, then they will be encouraged to discuss with their line manager, who will be able to provide additional support and answer any questions. It may be appropriate for their line manager to arrange some time to go through the guidance with them, or we can investigate a “buddy” system to pair them up with someone else who speaks the same language where possible. The NHS have also provided basic COVID information in a range of languages and this can be accessed on the Gov.Uk website.
|Sex, gender and gender identity (including men, women, non-binary and transgender people), and pregnancy and maternity (including women’s right to breastfeed).||Women are more likely to be the primary carer for a child or family member, and therefore may be more likely to need to take time off to care for people if they fall ill or are asked to self -isolate, or where their children have been told to stay at home as a result of a positive test within their child’s “bubble”.|
Mitigation – Parental Leave and Time Off for Dependents policies are in place which allow for staff to take time off in these situations. In the case of serious illness, the Compassionate Leave, which allows for some paid leave, may be relevant. The provisions under Parental Leave and Time Off for Dependents are unpaid, but it may be possible for some staff to continue to work from home, which will be considered on a case by case basis but may be less possible for staff working in customer -facing roles. Taking the time off as TOIL or holiday, including borrowing holiday from the next holiday year, will also be considered, as well as spreading deductions over a number of months including after they have returned to work. we would then discuss with them how this could be managed.
|Sex, gender and gender identity (including men, women, non-binary and transgender people), and pregnancy and maternity (including women’s right to breastfeed) (continued):||Pregnant women have been highlighted as at greater risk and are in the clinically more vulnerable group.|
Mitigation – The current guidance from the government does not recommend that pregnant women self-isolate or not return to work (unless they have any symptoms, live in a household where someone has symptoms or they have been told to do so by Test & Trace ), but they have been advised to rigorously follow the social distancing guidance. We aim to ensure that all staff can maintain a 2m distance from their colleagues at all times so this will also apply to those people who are preg nant anyway, and personal masks will also be provided. Line managers will have conversations with their teams, following guidance provided by HR, about their individual circumstances, and those in the clinically vulnerable group will be offered the option of the safest available on-site roles, enabling them to stay 2m away from others. If due to the nature of their role, they can continue to work from home then they should be supported to do so, although that may not be possible for the majority of roles which are customer-facing. Regular risk assessments are carried out during someone’s pregnancy anyway, so these will be reviewed in light of returning to library buildings; as the services we provide develop; and also as the pregnancy progresses.
|Sexual orientation and marriage/civil partnership:||None identified|
|Other socio-economic factors such as families, carers, single people/couples, low income, vulnerability, education, reading/writing skills, ‘digital exclusion’ and rural isolation.||Those with caring responsibilities where the care facilities close as a result of positive tests may find it more difficult to attend work in the library building if they cannot leave children/other dependents alone. This may be particularly difficult for single parents. Our figures show that about a fifth of our staff are the primary carer for a child/children under 18 years.|
Mitigation – Parental Leave and Time Off for Dependents policies are in place which allow for staff to take time off in these situations. The provisions under Parental Leave and Time Off for Dependents are unpaid, but it may be possible for some staff to continue to work from home, which will be considered on a case by case basis but may be less possible for staff working in customer -facing roles. Taking the time off as TOIL or holiday will also be considered, as well as spreading deductions over a number of months including after they have returned to work. we would then discuss with them how this could be managed.
|Those with a lower income are more likely to not have access to internet and other equipment at home, so not be able to work from home, or not be able to work as effectively. Also, those with less well-developed IT skills may have found it more difficult to work from home, even if they have access. Returning to library buildings will therefore have a positive impact on these people’s ability to work more easily and efficiently.|
|Other socio-economic factors such as families, carers, single people/couples, low income, vulnerability, education, reading/writing skills, ‘digital exclusion’ and rural isolation. (continued):||Those with lower incomes may be more likely to not run a car and therefore rely on public transport to get to and from work.|
Mitigation – the government advice is that public transport should be avoided where possible, and this will be part of the conversations that line managers will have with their teams – other options may include car sharing (where this can be done safely), or walking or cycling to work. Where public transport is the only option, then they will consider with them other options, such as changing their working hours so they can travel at less busy times or combining their hours so that they have to travel to work on less days if either of these are possible whilst maintaining the library opening times. Staff will be directed to the relevant government guidance, and all staff are being provided with personal masks and visors for work so they can also use these on public transport as well.
|Other socio-economic factors such as families, carers, single people/couples, low income, vulnerability, education, reading/writing skills, ‘digital exclusion’ and rural isolation. (continued):||Those with lower incomes may not have access to the internet at home, and therefore may find it harder to book a coronavirus test quickly.|
Mitigation – If someone is unable to book a coronavirus test online, then they can contact 119 to book a test by phone. Their line manager can also offer to support them in booking a test online if they feel comfortable doing that.
|Human rights considerations:||None identified|
Section 4b – Environmental impacts
An impact assessment should give due regard to the following activities in order to ensure we meet a range of environmental legal duties.
The policy or practice does not require the identification of environmental impacts using this Impact Assessment process because it is subject to (please select from the table below and proceed to the 4c, otherwise complete the environmental analysis table):
|Devon County Council’s Environmental Review Process for permitted development highway schemes.|
|Planning Permission under the Town and Country Planning Act (1990).|
|Strategic Environmental Assessment under European Directive 2001/42/EC “on the assessment of the effects of certain plans and programmes on the environment”.|
|Describe any actual or potential negative consequences.|
(Consider how to mitigate against these).
|Describe any actual or potential neutral or positive outcomes.|
(Consider how to improve as far as possible).
|Reduce waste, and send less waste to landfill:||Increased use of disposable equipment, such as gloves and cleaning wipe, will result in more waste being created.|
Mitigation – where possible, reusable equipment (e.g. masks and visors) will be provided to individual staff which can be washed between uses. Although single use gloves will be provided, people will not be encouraged to use these and will be advised to wash their hands regularly as the best protection. Although there is likely to still be an increase in waste (e.g. increased paper towel usage rather than using normal towels, increased waste bottles for hand sanitiser etc), this is necessary to ensure the safety of staff and customers.
|Conserve and enhance biodiversity (the variety of living species):||None identified||None identified|
|Safeguard the distinctive characteristics, features and special qualities of Devon’s landscape:||None identified||None identified|
|Conserve and enhance the quality and character of our built environment and public spaces:||None identified||None identified|
|Conserve and enhance Devon’s cultural and historic heritage:||None identified||None identified|
|Minimise greenhouse gas emissions:||More people returning to work from library buildings rather than working from home will increase greenhouse gas emissions if they commute by car.|
Mitigation – staff will be encouraged to travel to work by walking or cycling where that is possible, and we will look at supporting the secure storage of bikes on a library by library basis. Staff will be encouraged to continue to use online meeting facilities, access to which has been improved as a result of the lockdown, to hold meetings with people in other libraries rather than travel.
|Minimise pollution (including air, land, water, light and noise):||None identified||None identified|
|Contribute to reducing water consumption:||Increased handwashing will result in a rise in water usage.|
Mitigation – handwashing with soap and water is the most effective method of killing the virus, and staff will be encouraged to do this regularly throughout the day regardless of the other restrictions in place. Although this will increase water consumption, it is vital to keep staff safe.
|Ensure resilience to the future effects of climate change (warmer, wetter winters; drier, hotter summers; more intense storms; and rising sea level):||None identified||None identified|
|Other (please state below):||None identified||None identified|