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Skills Strategy: Draft Equality Impact Assessment (EQIA)
A NIACE response to the DfES consultation
Published: April 2007
1. About NIACE
1.1 The National Institute of Adult Continuing Education (NIACE) is an independent non-governmental organisation and charity. Its corporate and individual members come from a range of places where adults learn: in further education colleges and local community settings; in universities, workplaces and prisons as well as in their homes through the media and information technology. NIACE's work is supported by a wide range of bodies including the DfES (with which it has a formal voluntary sector compact) and other departments of state, by the Local Government Association and by the Learning and Skills Council. The ends to which NIACE activities are directed can be summarised as being to secure more, different and better opportunities for adult learners, especially those who benefited least from their initial education.
1.2 Its activities include: advocacy and policy responses; consultancy; specialist advice and support; running networks; research and development; publications; conferences, commissions and promotion (including Adult Learners Week). The website is
www.niace.org.uk.2. General responses
2.1 NIACE welcomes this work by the DfES to produce an equality impact assessment of its Skills Strategy. We recognise that this is a new area of development in public policy and that the draft document is to some extent ‘work in progress’. We believe that the approach adopted is workable and helpful – to define the equalities being examined, identify the evidence, develop impact criteria and then consider the different strands of the Skills Strategy in relation to the criteria. The technical document that has been developed to date is thorough and well produced whilst recognising in parts that more information, better data and additional evidence is required to measure the full impact of the Skills Strategy in relation to equalities. Some conclusions are inevitably tentative at this stage.
2.2 In general, the criteria developed for race, gender and disability are sound and comprehensive (though some adjustments are suggested in 3.1 and 3.2 below). They are key to any equality impact assessment. We particularly favour those about benefiting society as a whole by encouraging participation in public life.
2.3 However, we would argue that the final document might as well be prefaced with the phrase 'Subject to funding' since the DfES itself acknowledges a 'higher level of [legislative] duty to young people'. The Skills Strategy is pursued 'as resources allow' - that is, after commitments to the 16-18 age group are met - and therefore its accompanying impact on inequalities will also inevitably be affected. In essence, the criteria are all predicated on sufficient funding for the Skills Strategy overall (once the greater emphasis on the 16-18 age group has been satisfied). Because of this, its positive impact on decreasing inequalities remains something of an aspiration.
2.4 We are also concerned that adopting an approach that examines the Skills Strategy strand by strand is in danger of ‘not seeing the wood for the trees’. Clear evidence is emerging that the Skills Strategy, with its narrow focus for example on Skills for Life and ‘full fat’ Level 2 is having and will continue to have a devastating impact on adult learning and skills, in effect narrowing opportunities, including in the realm of 'First steps learning'. If the Skills Strategy decreases the overall volumes of adult learners, then that could well widen disparities and increase inequality overall.
2.5 In terms of the criteria, a phrase similar to the following recurs throughout the document:
‘Using these criteria, and on the basis of evidence currently available, we consider that the [identified strand in the Skills Strategy] is unlikely to have an adverse impact on disability equality, gender equality or race equality, and that on the contrary it has the clear potential to reduce inequalities in all three respects’.
Concentrating on the various component strands, this may be the case in some instances, but we believe that it masks continuing inequalities in the ‘bigger picture’. To take the example of ‘Level 2 qualifications as a platform for employability’ (Section 5.3), the evidence presented and available may show that take up is at least not increasing inequalities, but it ignores that the strand itself, in the way it is designed to meet the PSA target (‘full fat’ Level 2 for those who have no previous level 2 component to their education and training) neglects some of those groups at whom it is targeted. This point is further explored and developed in section 3.4 below.
2.6 NIACE has identified groups which the Skills Strategy may neglect. Among these groups are:
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older workers |
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part-time and temporary workers |
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those employed in businesses that are cool to training; |
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migrants (especially from EU accession countries) |
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women (especially from ethnic minority communities culturally resistant to high levels of female employment outside the home) |
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people currently on welfare benefits – especially those on Incapacity Benefits as a result of mental health problems; |
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ex-offenders; |
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adults with literacy levels at and below ‘entry level 2’. |
It would be beneficial to review the draft Equality Impact Assessment document in relation to these groups as well as in relation to the identified equalities – race, gender and disability – and to look at how the various strands of the Skills Strategy are delivered. Are they within reach of potential learners learning in small ‘chunks’ over a protracted period and fitting their learning around work, family and other commitments?
2.4 We understand the rationale that the DfES has adopted for the equality strands it has identified – race, gender and disability. We believe that the impact of others – age, sexual orientation, religion or belief and even marital status – will need to be considered in the future. The issue of religion or belief is important, certainly in relation to Islam and possible prejudice. It has been considered in the document (e.g. in the race equality criteria) but could be developed more.
2.7 We recognise that the draft Equality Impact Assessment document is technical, and recommend that when the current version is finalised an easily accessible guide and a commentary be produced. We assume that the final version will mark the start of a journey of regular revisions as evidence becomes firmer and policy and practice develop.
3. Specific responses (NB not every section is addressed)
3.1 ‘Criteria for disability equality impact assessment’ (section 2.2.6)… We are doubtful about the phrase ‘Benefit all members of the workforce involved in delivering the Strategy…’ on the grounds that this suggests that they are active agents in this and know that that is what they are doing. ‘Benefit all members of the workforce whose position is influenced by the strategy’ might be better. We also firmly recommend the insertion of ‘and potential members’. The criterion could read: ‘Benefit all members and potential members of the workforce whose position is influenced by the Strategy, whether or not they are disabled’.
3.2 The equivalent criteria in sections 2.2.7 (gender equality) and 2.4.5 (race equality) we believe should also be adjusted to include ‘and potential members’. Note here that the document itself refers to the wrong sections for the sets of criteria (i.e. not 2.2.4, 2.3.4 and 2.4.4) and there is some mis-numbering on pages 18 and 19.
3.3 Aspects of section 2.5.1 on age equality are disappointing, particularly concerning grants and loans for tuition fees and maintenance. It is well recognised that older adult learners are disadvantaged in this area and that the DfES is taking refuge in a legal position that such funding falls outside the scope of the age regulations. In addition, to state that the ‘regulations do recognise that certain age-related practices may be justifiable where they are a proportionate means of achieving a legitimate aim’ rather undermines the thrust of a document devoted to equality impact assessment and does not acknowledge Britain’s changing demographic profile (although this is acknowledged elsewhere). NIACE would welcome further future development of section 2.5 (A note on age equality) to address fully this important strand.
3.4 In section 3.2.6 is an example of how a seemingly useful strategy does not necessarily have straightforward benefits. The first part of 3.2.6 states: ‘The core element of free tuition up to a first full Level 2 qualification will benefit low skilled employees who are more likely to be older, female and/or from ethnic minority groups’. The evidence to support this for the three equality strands identified is not precise. The notion of Level 2 as a gateway to employability is probably sound, as is the target group. The problem is that the detail of the policy and Level Two entitlement (‘full fat’ Level 2, 'first' Level 2) has the effect of excluding the target group because of the configuration of the entitlement. The target learners are more likely to want and need to undertake learning in small ‘chunks’ over a protracted period and on a part time basis, fitting learning into all their other work, family and other commitments. The prospects for learners trying to make progress in this way do not look favourable. They would be assisted by the rapid development of the Qualifications and Credit Framework only if the funding regime could be 'configured' to make this possible - a genuinely supply-side rather than demand-led approach.
3.5 The section Investors in People (3.5) refers to a research report on diversity. Amongst the conclusions, it was noted that some organisations have little intention of becoming fully diverse, that extra IiP measures on recruitment should not involve extra cost etc. There was also little exploration of the contentious concept of ‘the best person for the job’. We believe that the DfES response (section 2.5.8) is too passive and that it is not enough to encourage IiP to include diversity in the Standard given the constraints identified by the research. More effective ‘levers of change’ should be applied.
4. Evidence in the draft EQIA document
4.1 There is a good range of statistical data, the sources of which (in the main text, in footnotes and in Appendix A) should all be included in the bibliography, Appendix C. There are some good references to qualitative evidence in the bibliography as well as the quantitative, statistical evidence.
4.2 However, the impact assessment is at present based more on quantitative evidence (however incomplete) than qualitative evidence - on what is happening on the broader scale (i.e. across England) rather than how recent changes have an impact at the individual level. It can be argued that the broader scale is ultimately composed of thousands of individual biographies and case studies. Unless we pay attention to what is happening at the individual level in terms of the intricacies of impact, motivation and action at the very least, we will have an incomplete picture of why the broader picture is as it is. Appendix A contains some references to biographical research that may be of some general use. Biographical research in relation to the Skills Strategy may be helpful for future development.
5. Summary and conclusion
5.1 NIACE welcomes the draft Equality Impact Assessment document and believes that the approach adopted has much value.
5.2 The criteria developed so far are sound, though we propose some adjustments and recommend further attention to the 'Note on age equality'.
5.3 We believe that the impact assessment inevitably suffers from the same issues facing the Skills Strategy itself - that it is undermined because it is predicated on and disadvantaged by other funding priorities (i.e. the 16-18 strategy).
5.4 There is a danger that the 'strand by strand' approach will obscure the possibility that the Skills Strategy overall may actually be likely to have an adverse impact on equality and that its potential to reduce inequality is not as clear-cut as argued.
5.5 'Drilling down' into some strands in more detail, the way they are delivered is as important as what they deliver. Taking the Level 2 Entitlement as an example, adopting a 'first', 'full fat' approach and requiring Level 2 to be acquired in a conventional way may exclude many of those in the target group who are not able to learn in such a 'tidy' fashion.
5.6 We suggest that the document could be 'audited' for impact assessment using the groups NIACE believes that the Skills Strategy neglects.
5.7 Acknowledging that the document is 'work in progress', we advise further development related to other equalities than the ones currently identified.
5.8 There should be an accessible guide and commentary for the final document.
5.9 In section 3, we make specific comments and in some cases suggestions about the criteria, age equality, Level 2 and Investors in People.
5.10 The evidence underpinning the impact assessment we believe is good, but we favour more use, exploration and application of available qualitative evidence (e.g. biographies and case studies).
5.11 Overall, this Equality Impact Assessment document is a welcome development in policy. Monitoring and review in the light of new evidence and further evolution in the field of equality and diversity will highlight how effective and transformational it will be. In this field, NIACE believes that we are at the beginning of a journey. The destination seems clear, but the route towards it will be subject to changes along the way.
Appendix A
Alheit, P., Andersen, A.S., Merrill, B and West, L. (eds) (2007.) Using Biographical and Life History Approaches in the Study of Adult and Lifelong Learning: European Perspectives. Berne/Switzerland, Peter Lang.
Bassey, M. (2003.) Case Study Research in Educational Settings. Maidenhead and Philadelphia, Open University Press.
Chamberlayne, P., Bornat, J. and Wengraf, T. (eds) (2000.) The Turn to Biographical Methods in Social Science; Comparative Issues and Examples. London, Routledge.
Clandinin, D.J. and Connelly, F.M. (2000.) Narrative Inquiry: Experience and Story in Narrative Research. San Francisco, Jossey-Bass.
Dominice, P. (2000.) Learning from Our Lives: Using Educational Biographies with Adults. San Francisco, Jossey-Bass.
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The full consultation document can be found on the DfES website
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