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Equality and diversity action plan 2011/2012

 

This action plan is structured to follow the SRA's business plan which sets out four business objectives for the SRA in 2011/12, namely:

  1. Outcomes-focused regulation (OFR)
  2. Organisational reform
  3. Be a recognised and respected regulator, and
  4. Enhanced client/consumer protection

The actions identified are also designed to deliver against our nine equality objectives and incorporate the actions that the SRA has accepted following the recommendations made in the Pearn Kandola report. All actions arising from recommendations made in the report are marked with an asterisk (*).

Business objective 1: Outcomes-focused regulation (OFR)

No. Actions Responsibility Measures and milestones
1.1 Assess the new SRA Handbook for its impact on equality and human rights. Executive Director of Supervision Risks and Standards
1.2 Assess our approach to outcomes-focused regulation for its impact on equality and human rights, in particular through our development of the Risk Centre, and our three main functions: authorisation, supervision and legal enforcement Executive Director of Supervision Risks and Standards and Chief Operating Officer/Executive Director Authorisation
  • The new SRA functions are developed taking into account equality and human rights issues.
  • The equality and human rights impact assessments of our three main functions are published by September 2011 and any actions are taken forward.
1.3 Assess the equality and human rights impact of the introduction of alternative business structures (ABS) and the arrangements being made for the SRA to regulate them Executive Director of Supervision Risks and Standards
  • The SRA Handbook and our practical arrangements for regulating alternative business structures are developed taking into account equality and human rights issues.
  • The equality impact assessment of ABS is published by March 2011 and any actions are taken forward.

Business objective 2: Organisational reform

Data collection and equality monitoring
No. Actions Responsibility Measures and milestones
2.1 Continue to record sufficient data to identify the source of all referrals we receive, recording diversity data where possible, to enable us to monitor those organisations or individuals by equality group*. Chief Operating Officer/Executive Director Authorisation
  • The SRA is recording and monitoring by equality group, where possible, all referrals received.
2.2 Improve the diversity monitoring data we hold for the profession, including solicitors and office holders and workforce diversity monitoring data for regulated firms in line with the Legal Services Board's (LSB) requirements. Chief Operating Officer/Executive Director Authorisation
  • The SRA is collecting and monitoring diversity data for regulated individuals across all equality groups at key points of contact with the SRA (including student enrolment, admission to the Roll, practising certificate renewal, and at the point of authorisation).
  • Regulated individuals can access their records at any time and submit or update their diversity data online.
  • There is an increase in the amount of data held for regulated individuals across all equality groups.
  • The SRA is complying with the LSB's requirements for reporting diversity monitoring data of regulated firms by 2012 or as required by the LSB.
2.3 Continue to work with the Legal Ombudsman regarding referrals to the SRA*. Chief Operating Officer/Executive Director Authorisation
  • There are clear arrangements in place for the Legal Ombudsman to refer cases to the SRA and for the appropriate exchange of information.
  • The SRA is monitoring the referrals data coming from the Legal Ombudsman by equality group.
2.4 Improve the way that we record our regulatory activities to facilitate improved equality monitoring across all work areas*. Chief Operating Officer/Executive Director Authorisation
  • The SRA publishes data in relation to key areas of its regulatory activities broken down by age, disability, ethnicity and gender by July 2012.
  • The SRA publishes data about other areas of activity (such as authorisation and compensation fund claims) by age, disability, ethnicity and gender by July 2013.
Equality in the workforce and diversity at SRA Board and Committees
No. Actions Responsibility Measures and milestones
2.5 Develop positive action proposals for recruitment, retention and progression of SRA staff. Director of Human Resources
  • The SRA will seek to increase the employment applications received from disabled people by 2% in 2011 and 4% in 2012.
  • The SRA will introduce between five and ten work experience placements for disabled people by December 2012.
  • The SRA will increase the appointment of disabled employees from the current figure of 4%
  • The SRA will increase the appointment of BME employees at grades G to L by 2% in 2011 and 4% in 2012.
  • The SRA will encourage broader diversity in the applications received across different BME groups.
  • The SRA will introduce a talent management programme for BME and female staff to include provision of additional training and secondments.
  • The SRA will carry out research to ascertain why response rates in relation to our diversity monitoring are low for certain diversity categories (in particular sexual orientation) and formulate a plan to increase response rates from employees.
  • The SRA will implement a graduate recruitment scheme with five places to be made available for graduates in 2012.
  • The SRA will complete a Workplace Equality Index for Stonewall in 2011 and for Opportunity Now and Race for Equality in 2012.
2.6 Publish workforce diversity monitoring data in accordance with our public equality duty. Director of Human Resources
  • The SRA publishes workforce diversity monitoring data for the following categories by July 2011:
    • All employees
    • All job applicants
    • Successful job applicants
    • Disciplinary actions
    • Employees placed on performance improvement/capability review
    • Grievances
    • Leavers
    • Promotions, and
    • Training
  • SRA workforce diversity monitoring data for the following further categories is published by December 2011:
    • Maternity and those returning to work
    • Employees by grade and pay scales
    • Sickness absence rates
    • Flexible working
    • Performance development review outcomes
2.7 Implement actions in relation to improving dignity at work arising from the 2010 staff survey results and repeat the survey for 2011 Director of Human Resources/ Director of Inclusion
  • Equality and diversity workshops are available to staff by September 2011, focusing on behaviour and how to tackle bullying and harassment.
  • Improved guidance and support is available for staff in challenging bullying, harassment or discrimination available by September 2011.
  • A policy for managing unreasonable behaviour from our customers is in place by July 2011.
  • The results of the 2011 staff survey indicates a downward trend in the findings relating to bullying and harassment.
2.8 Deliver focused training on decision making and leadership for senior managers and decision makers Director of Human Resources/ Director of Inclusion
  • Training on decision making for the SRA's senior management team and the SRA's leadership group is delivered by the end of July 2011 and for other managers and decision makers by the end of March 2012.
  • A two-day leadership development workshop will take place in July 2011 for the senior management team and the leadership group.
2.9 Deliver a range of training and development programmes to build the competence and confidence of staff on equality, diversity and human rights Director of Inclusion
  • All staff will have completed a mandatory e-learning training module on equality and diversity by the end of May 2011.
  • All decision makers at the SRA will have received mandatory training on human rights by October 2011.
  • A range of specialist equality and human rights courses will be available for staff throughout the year.
  • The SRA staff attitude survey for 2011 will show that staff have an improved understanding of their role in delivering equality and diversity.
2.10 Deliver a range of diversity-related events for staff to raise awareness of equality and diversity Director of Inclusion
  • The SRA will hold an event to celebrate International Women's Day in March 2011.
  • The SRA will hold an event to celebrate Black History Month in October/November 2011.
  • The SRA will hold an event to celebrate Human Rights Day in December 2011.
  • There will be improved awareness of the SRA's Equality Framework measured through the staff survey results for 2011.
2.11 Introduce equality champions to support equality and diversity initiatives across the business Director of Inclusion
  • The SRA will have equality champions recruited and in place with clear objectives by March 2012
2.12 Promote diversity at Board and Committee levels Director of Inclusion/ Board support
  • There will be improved diversity in the pool of applicants for the two SRA Board vacancies arising in 2011 and any other vacancies for the Board or committees arising in 2011/12.
  • Diversity data for the SRA Board and Committees will be published by September 2011.
2.13 Assess the equality and human rights impact of the new organisational structure and the proposed move to a single site Director of Human Resources/ Chief Operating Officer/Executive Director of Authorisation
  • Organisational restructure completed taking into account equality issues identified through the ongoing equality impact assessment work.
  • Organisational restructure EIA published for staff.
  • Move to a single site completed taking into account equality issues identified through the ongoing equality impact assessment work.
  • Single-site EIA published for staff.
Procurement
No. Actions Responsibility Measures and milestones
2.14 Review the SRA's procurement function and publish guidance for staff on best practice in promoting equality and diversity in procurement Director of Inclusion
  • Equality and diversity is embedded in the SRA's procurement processes.
  • Internal staff guidance is made available to staff by September 2011.

Business objective 3: Be a recognised and respected regulator

Communications and engagement with our external stakeholders
No. Actions Responsibility Measures and milestones
3.1 Review and improve our website and our external digital communications Director of Communications/ Chief Operating Officer/Executive Director Authorisation
  • The SRA website and digital communications are more accessible, to be measured through customer feedback from consumers and the profession.
  • An equality impact assessment of the SRA's website and digital communications will be published by December 2011 and the actions taken forward.
  • Student enrolment applications will be available online by February 2011.
  • Other applications available to the profession online from July 2011.
3.2 Develop and establish the SRA's consumer affairs function and strategy Director of Inclusion
  • The SRA will develop and establish a web-based consumer stakeholder network by December 2012.
  • The SRA will publish a consumer affairs strategy and action plan by July 2011
  • The SRA will work with the Legal Services Board Consumer Panel on a joint project to understand the experience of disabled consumers in the legal services market.
  • The SRA will hold a consumer engagement event in September 2011.
3.3 Develop and publish an inclusive stakeholder engagement strategy for the SRA Director of Inclusion
  • The SRA has a published engagement strategy by July 2011.
  • At least three engagement events are held jointly with equality groups for 2011 and for 2012.
3.4 Support small firms to manage the transition to outcomes-focused regulation and the introduction of alternative business structures through a variety of engagement events Director of Inclusion/ Director of Communications
  • The SRA has delivered a series of webinars and roadshows across England and Wales by September 2011.
  • The SRA is engaging closely with the Sole Practitioners Group (SPG), attending regular meetings as well as the SPG's annual conference.
Encouraging equality of opportunity and respect for diversity in the profession
No. Actions Responsibility Measures and milestones
3.5 Provide information about compliance with rule 6 under the current Code of Conduct Director of Inclusion
  • The SRA's annual reports for 2009 and 2010 on compliance with rule 6 are published by July 2011.
3.6 Ensure that the profession is meeting principle 9 and the equality and diversity outcomes in chapter 2 of the new SRA Code Director of Policy and Standards/Director of Inclusion
  • Publish frequently asked questions on the website about compliance with principle 9, and chapter 2 of the new SRA Code by September 2011.
  • Develop our approach to supervision of firms in relation to principle 9 and chapter 2 through a thematic supervision pilot.
Education and training
No. Actions Responsibility Measures and milestones
3.7 Review the level of support and supervision given to trainee and newly qualified solicitors and the SRA's process for supervising and monitoring firms in relation to this* Executive Director of Supervision Risks and Standards
  • A full review of the educational requirements placed upon individuals entering the sector (including programmes and pathways to professional qualification) and well as the training contract will produce recommendations by December 2012.
  • A revised approach to the SRA's supervision of firms with trainees is in place by October 2011.
Encouraging equality of opportunity and respect for diversity in the profession
No. Actions Responsibility Measures and milestones
3.8 Review the ongoing accreditation and Continuing Professional Development (CPD) of solicitors* Executive Director of Supervision Risks and Standards
  • More effective and focused continuing professional development training proposals are in place for the profession by the end of 2012 to include appropriate arrangements for training on equality and diversity.
3.9 Review the Qualified Lawyers Transfer Scheme (QLTS) Executive Director of Supervision Risks and Standards
  • The Qualified Lawyers Transfer Test (QLTT) is reviewed for its equality impact and the EIA published by February 2012, and any proposed actions taken forward.
Review of regulatory decision making
No. Actions Responsibility Measures and milestones
3.10 Review specified aspects of the SRA's regulatory decision-making in accordance with the recommendations made by Pearn Kandola Executive Director Resources/ Executive Director Legal and Enforcement
  • An audit of decisions made about taking forward matters referred to the SRA is concluded by June 2011.
  • An audit of decisions in relation to the outcome of cases where a breach of the Code of Conduct is alleged is concluded by June 2011.
  • An audit of decisions to refer a case to the Solicitors Disciplinary Tribunal is concluded by April 2011.
  • An audit of decisions to impose practising certificate conditions is concluded by April 2011.
  • An audit of decisions in relation to accounts and approvals to be concluded by October 2011.
  • An audit of decisions to refer cases for adjudication at committee or panel level to be concluded by June 2011.
3.11 Provide an update on progress against the recommendations made in the Pearn Kandola report about disproportionate outcomes for BME solicitors Director of Inclusion
  • A progress report is published by September 2011.
3.12 Continue with our decision-making project to assess the equality impact of our decision-making criteria All Executive Directors
  • The SRA decision-making criteria are reviewed for their equality impact and the equality impact assessments are published in accordance with our EIA schedule for 2011.
Disability equality—better understanding the needs of our stakeholders
No. Actions Responsibility Measures and milestones
3.13 Evaluate the effectiveness of our reasonable adjustment policy Director of Inclusion
  • A report on the provision of reasonable adjustments at the SRA is published by December 2011 and any recommendations taken forward.
3.14 Continue to monitor the provision of reasonable adjustments by Legal Practice Course providers for disabled students Executive Director of Supervision Risks and Standards
  • A report on the provision of reasonable adjustments by LPC providers is published by July 2011 and any recommendations taken forward.
3.15 Introduce a scheme for disabled people in communicating with us through our regulatory work (external liaison scheme). Director of Inclusion
  • The SRA has an external liaison scheme available for use by disabled solicitors and others by September 2011.

Business objective 4: Enhanced client/consumer protection

No. Actions Responsibility Measures and milestones
4.1 Publish statistics about the Assigned Risks Pool (ARP) and the ARP enforcement strategy regularly, and support firms where we can in getting out of the ARP Chief Operating Officer/Executive Director Authorisation
  • Information about the Assigned Risks Pool (ARP) and the ARP enforcement strategy is available on the SRA website by August 2011.
  • Firms in the ARP are risk-assessed promptly and provided with support where appropriate to plan their exit from the ARP.
4.2 Assess the proposed changes to client protection proposed for 2011/12 and beyond Executive Director of Supervision Risks and Standards
  • Future client financial protection arrangements are developed taking into account the equality issues identified through the equality impact assessment.
  • The equality impact assessment is published by April 2011 and any actions are taken forward.