Equality impact assessment

Digital communications

Business unit: Communications
Publication date:  December 2011

Introduction

In line with our Communications strategy, we have utilised a number of digital means to meet our objectives. This consists of e-marketing and, very recently, social media and webinars. Therefore, this impact assessment will cover

• social media, specifically Twitter, YouTube and LinkedIn
• webinars, and
• e-marketing.

Our website is not covered in this equality impact assessment (EIA). A separate initial EIA was carried out in 2009 and this EIA will be reviewed again in 2012.

Aims and objectives

Our main aim is to achieve an effective, transparent and consistent communications approach in all of our digital communications.

Our other aims and objectives are

• to raise awareness and understanding of the SRA and its work with stakeholders and to position the SRA as a regulator of choice
• to improve communication with the profession, and support engagement with the profession over changes to the regulatory regime
• to provide information to help consumers make decisions about legal services and understand the standards and outcomes that they are entitled to expect from the profession, and
• to ensure that we are inclusive across all audiences, in line with our Equality Framework.

Key stakeholders

The key stakeholders have been identified as

• solicitors and providers of legal services
• education and training providers and students
• consumers of legal services
• SRA staff
• parliamentary/political stakeholders and other government organisations
• media
• commercial interests
• other legal regulators including the Legal Services Board
• other regulators
• solicitor representative groups, including the Law Society
• equality and diversity groups
• legal complaints bodies (such as the Legal Ombudsman)

Background

We ensure that our style of communication is targeted. We have identified five key audiences as

• staff, the profession and its representative bodies
• training providers, students and trainees
• the public, consumers of legal services and consumer groups
• the political community, and
• other stakeholders such as the Legal Services Board and other regulators.

We have adopted a number of methods to improve and ensure inclusive communication with stakeholders, as follows:

• Social media—We have our own Twitter account, where we publish updates, and currently have more than 3,700 followers. We have also published videos on YouTube of Chief Executive Antony Townsend and other SRA representatives delivering key messages. Since 27 January 2011, there have been 10,387 views of the videos uploaded by the SRA, 5,362 of which were directly through the SRA website; 870 were viewed on mobile devices. We are also represented on LinkedIn and have over 150 "connections", although this is not an official presence controlled by the SRA.
• Webinars—Webinars are a form of virtual lecture or presentation/seminar delivered digitally over the internet. Slides are transmitted to those "attending" the webinar and the presenters give the lecture over the top of these slides which is transmitted via the attendees' computers, allowing access to the material from remote locations. We have held 15 webinars and have made the slides and materials available on our website for stakeholders to access after the live webinar has finished.
• E-marketing—E-marketing involves bulk emailing multiple users at the same time with the same information. In line with the Law Society standards for e-communication (PDF, 10 pages, 125K), We send out various e-communications to our stakeholders. The current bulk mailings are as follows:
  • SRA Update—This is sent to around 160,000 regulated individuals, four to five times per year. Recipients can opt out of the bulk mailing, and unregulated individuals can opt in to receive the information.
  • SRA consultation alerts—Alerts are sent to around 3,000 opted-in subscribers when new consultations are opened to the public.
  • Targeted messages—These are sent to a targeted sector of the profession, depending on the aim of the message. The size of the mail -out can therefore vary from 100 to 100,000.

Equality impact

We want to ensure that we are inclusive in our digital communications work, and work towards ensuring that our communications reach the widest audience is crucial in achieving this.

Each of the digital communication methods used will be addressed separately to effectively consider the impact.

Social media

The SRA has not sought to use social media as a direct-influence tool. Instead, we have used it as a "push" channel to promote content published on our website.

Some research conducted by other organisations provides an indication of the demographics of users of social media.

Twitter

There is very little demographic data available for Twitter, as the website works on a self-disclosure basis and does not ask for diversity data from its users. Because of this, it is not possible to accurately measure whether Twitter, and thus our presence on Twitter, is being accessed by a diverse population. However, Pingdom has produced the data below with regard to the age and gender of Twitter users.

With regard to accessibility, Twitter itself does not conform with some of the key Web Content Accessibility Guidelines 2.0 success criteria and is not generally considered to be accessible to visually impaired users. However, there are separate accessible platforms that allow users to access Twitter content and functionality. For example, Easychirp allows users with disabilities to sign in to Twitter and access content and functionality via a platform that meets very high accessibility standards. Easychirp is an award-winning site, and was the Royal National Institute for Blind people (RNIB) featured site for December 2011.

YouTube

There is limited data available regarding the demographics of YouTube users, and what data is available seems to relate to users from the USA. However, the data available from Slideshare provides a picture of YouTube users.

LinkedIn

Demographic data is available for LinkedIn, as this is used as a recruitment tool; user profiles are encouraged to disclose gender, age and ethnicity. This data is therefore available for those with LinkedIn profiles. Only age and gender data is displayed in this EIA, as all of the data regarding ethnicity uses American categories of ethnicity and thus is not included in this report.

Although we cannot control who accesses social media sites, the available data points to a fairly representative sample of data. However, as there is no data available regarding other protected characteristics, it is difficult to state this is the case for all groups. Also, as this form of communication is supplementary to other forms of communication used by the SRA, the impact is considered minimal.

Webinars

Since December 2010, we have held fifteen webinars. Since May 2011, 3,433 people have attended an SRA-run webinar. We have diversity data for 32 per cent of those who attended. Of those, 21 per cent were black or minority ethnic (BME) and 71 per cent were white (8 per cent were of unknown ethnicity). There was an even split in terms of gender. One per cent of the attendees had declared a disability, 59 per cent stated they did not have a disability, and in 39 per cent of the cases we did not know the disability status. In order to maximise accessibility, webinars are uploaded to YouTube, which provides an option of subtitles for those who may have hearing impairments.

E-marketing

There are currently two regular e-marketing updates that we send, along with other "as required" mail-outs, with distribution lists ranging from a few hundred to 160,800. All communications of this type work on an opt-out or opt-in basis, with recipients choosing to remain on the distribution list.

SRA Update has the largest distribution, as it is sent to all regulated individuals who have not chosen to opt-out (currently 160,000 email addresses), along with a number of unregulated individuals, who opt-in to receive the email (around 1,000). Diversity data is available for regulated individuals through the SRA diversity data collected. However, the work involved in compiling this is not proportionate for this EIA.

There is no diversity data available for those who opt in to our mailing lists. We ensure that these emails are available in alternate formats, where requested in line with our Reasonable adjustments policy and language and translation policy. There have been no reasonable adjustment requests made directly to the Communications team. The team follow best practice in terms of HTML coding, and also provide a plain text version of all emails.

Ofcom have conducted some research on ethnic minorities and digital communication in the UK. They found that ethnic minorities are at the forefront of media take-up and use. They also found that ethnic minorities are more likely to download audio and video content and that ethnic minority groups are less likely to participate in traditional media activities such as newspapers and magazines.

Conclusions

Social media

From the information we have considered, our use of digital communications does not seem to be causing any adverse impact on gender as there is an even split.

The information suggests, for Twitter, a positive impact for the 25–54 age bracket, as there is a higher percentage of users from these ages. There is a potential for adverse impact on 0–17 year-olds for Twitter, YouTube and LinkedIn. There are also less users from the 18–24 and 65+ age groups for Twitter, with only 3 per cent coming from these age groups.

We are not able to draw any firm conclusions with regard to ethnicity. However, the information from Ofcom suggests that there is a positive impact for this group.

With regard to webinars, there seems to be a positive impact for BME groups with 21 per cent attending the webinars, this compares to 12 per cent of the overall profession being BME.

Our data is limited for disability, so it is not possible to draw any firm conclusions about any impact. However, we take measures to ensure our webinars are as accessible as possible. There is a potential adverse impact on the 22–30 and 61+ age brackets as there is lower take-up for the webinars by those in these age ranges.

We do not identify any adverse impacts in relation to our e-marketing, particularly as we ensure our communications are available in alternative formats. We also take positive action measures such as targeted emails to representative equality groups to ensure our information is accessed by as many people as possible.

While we have identified some potential for adverse impact, this can be counteracted by the fact that, typically, we use more than one method of digital communication, including email, Twitter and information on the website (which is accessible for users of screen readers, and is also covered by our reasonable adjustments policy).