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Equality and diversity strategic action plan 2009—2011

The equality and diversity strategy and action plan for 2009-2011 has now been replaced by the Equality Framework.

In this action plan, we have set our 10 equality and diversity objectives that will help us towards becoming an organisation that is:

  1. A fair employer which recruits, develops and retains a diverse and talented workforce
  2. A fair regulator which is open, proportionate, non-discriminatory and transparent in the way it regulates a diverse profession
  3. An inclusive and stakeholder-focused organisation

Abbreviations

  • CEO, Chief executive officer
  • DWG, Diversity Working Group
  • E&D, Equality and diversity
  • EIA, Equality impact assessment
  • HRD, Human Resources and Development
  • SDT, Solicitors Disciplinary Tribunal
  • SMT, Senior management team

Objectives

Objective 1: organisational culture and leadership

We will provide visible and demonstrable leadership to ensure that equality and diversity is embedded into the culture and work of the SRA

Actions

Action Completion date Responsibility
1.1 Establish a Board E&D Group to progress the E&D Strategy Oct 2008 Chair and CEO
1.2 The CEO will chair the internal DWG Oct 2008 CEO
1.3 Develop positive action proposals to ensure we have a representative and diverse Board, Committees and workforce Jan 2009 and Sep 2009 Director of Policy (Inclusion)/Director of Group HRD
1.4 The SMT will embed E&D into their respective business plans Nov 2008 All directors
1.5 Communicate our E&D strategy and our values to all our staff and external stakeholders Apr 2009 Director of Policy and Communications
1.6 Include E&D competencies in the performance framework for all staff Dec 2008 and July implementation Director of Group HRD
1.7 Deal appropriately with and challenge inappropriate language and conduct Immediately All directors/HRD

Outcomes

  • The SRA Board, the CEO and SMT actively lead the promotion of equality and diversity in the SRA
  • E&D is demonstrably embedded into the organisations business plans
  • Demonstrable involvement and representation of diversity on the Board, Committees and within the workforce
  • E&D competencies are integrated into the competency framework and performance management system of the SRA
  • There is clear accountability for the delivery of the strategy and action plan.

Objective 2: being an employer of choice

We will work towards becoming an inclusive and responsive employer of choice with a workforce which reflects the diversity of the communities we serve

Actions

Action Completion date Responsibility
2.1 Initially equality impact assess, review and, where required, carry out a full impact assessment on HRD policies and procedures (to include recruitment and selection policies and procedures) 2009 and as per the HRD schedule of policy review Director of Group HRD
2.2 Embed E&D into the HRD strategy and policies Mar 2009 and ongoing  Director of Group HRD
2.3 Collect equality data and monitor outcomes of key HRD policies by equality strands (to include grievance and disciplinary policies) Ongoing–2011 Director of Group HRD
2.4 Carry out a staff attitude survey (to include questions about equality and diversity) every two years Oct 2009 Director of Group HRD
2.5 Develop proposals for improving the way we engage with staff, through staff networks or otherwise Initial meeting Mar 2009 and proposal in Aug 2009 Director of Group HRD / Director of Policy (Inclusion)

Outcomes

  • The SRA is seen by all prospective employees as an employer of choice
  • Employees take pride in and feel valued working for the SRA.

Objective 3: learning and development

We will provide staff and Board and Committee members with the skills, knowledge and confidence in implementing equality, diversity and human rights in their work

Actions

Action Completion date Responsibility
3.1 Provide learning and development on fair and effective recruitment for recruiting managers Aug 2009 Director of Group HRD
3.2 Carry out an equality training needs analysis to identify staff learning needs and deliver an ongoing learning and development programme on E&D and human rights Jun 2009 Director of Policy (Inclusion)
3.3 Embed equality and diversity where appropriate into all learning and development programmes May 2009 and ongoing Director of Policy (Inclusion)/Director of Group HRD
3.4 Implement a review system to assess the effectiveness of our E&D and human rights learning programmes May 2009 Director of Policy (Inclusion)/Director of Group HRD
3.5 Deliver equality impact assessment training workshops Feb 2009–Nov 2010 Director of Policy (Inclusion)
3.6 Provide ongoing learning and development for Board and Committee members Jun 2009 and ongoing Director of Policy (Inclusion)

Outcomes

  • Staff are provided with learning and development that is tailored to the jobs they do within the organisation
  • Staff have the skills, knowledge and confidence to work and interact with people from diverse backgrounds
  • Equality and diversity is integrated into all learning and development programmes.

Objective 4: strategic planning and policy development

We will assess our policies for their impact on equality and human rights to ensure we meet our general and specific equality duties

Actions

Action Completion date Responsibility
4.1 Develop and publish a two year EIA schedule for all existing strategies, functions, policies and procedures that need to be impact assessed Sep 2008 Director of Policy (Inclusion)
4.2 Conduct and publish an impact assessment (initial or full as appropriate) for all new policies, procedures, functions and strategies 2009–2011 All directors
4.3 Ensure all Board papers identify E&D implications Jan 2009 and Sep 2009 All directors/SRA Board
4.4 Review our EIA process to ensure human rights implications are considered Nov 2009 Director of Policy (Inclusion)

Outcomes

  • EIA is integrated into the strategy and policy development
  • EIA's are delivered in line with the published schedule
  • E&D is a key consideration and facet of strategic planning and policy development.

Objective 5: transparency and decision making

We will review our decision making policies and processes to ensure transparency and will develop and implement a complaints handling policy that is independent, fair, objective and transparent

Actions

Action Completion date Responsibility
5.1 Review our disclosure policy to ensure greater transparency in our regulatory activities May 2009 Director of Legal/ Director of Regulation Response
5.2 Publish our policies and criteria for decision making to ensure that the profession is aware of the way we deliver our regulatory responsibilities Jan–Dec 2009 Director of Policy and Communications/CEO
5.3 Implement a system of regulatory audit to ensure our regulatory decision making is fair and proportionate Mar 2009 All directors
5.4 Implement an interim protocol for handling complaints of discrimination made against the SRA by members of the profession and consumers Dec 2008 Director of Policy (Inclusion)
5.5 Provide ongoing training and support for complaints officers handling complaints of discrimination Jan 2009 Director of Policy (Inclusion)
5.6 Develop, implement and publish a comprehensive complaint handling policy and process Sep 2009 Director of Policy (Inclusion)/all Directors
5.7 Develop a mechanism to monitor complaints handling and to review the learning outcomes for the organisation Sep 2009 Director of Policy (Inclusion)/Chief Operating Officer

Outcomes

  • We will be seen by the diverse regulated community as a fair, transparent and proportionate regulator
  • The decisions we make will be fair, transparent and proportionate
  • The handling of complaints, including discrimination complaints, will be dealt with fairly and transparently through a central policy
  • Complaint handling will inform improvements in service delivery where appropriate.

Objective 6: research and data collection

We will undertake research and collect equality data to enable us to monitor and analyse the delivery of our regulatory activities and other functions

Actions

Action Completion date Responsibility
6.1 Carry out a data collection exercise to obtain accurate and up-to-date information on the six equality strands for the profession Jun 2009 Director of Information/Director of Policy (Inclusion)/ Director of Policy and Communications
6.2 Work with professional representative groups from the profession to encourage their members to complete the monitoring forms Jun 2009 Director of Policy and Communication / Director of Policy (Inclusion)
6.3 Develop a system to report annually on regulatory activities and decision making in relation to the profession Dec 2009 Chief Operating Officer/all directors
6.4 Carry out equality monitoring by six equality strands on SRA informants (someone who has made a complaint about a solicitor) Apr 2009 and ongoing Director of Regulation Response
6.5 Carry out research to better understand the issues of disproportionality and how the SRA is perceived by the profession Dec 2009 Director of Policy (Inclusion)
6.6 Carry out research on the experiences of stakeholders from equality groups who access and use legal services May 2009 Director of Policy and Communications

Outcomes

  • The SRA will be better informed of the reasons for disproportionality in its data
  • The monitoring of regulatory activity and collection of data will form a critical part of the organisations reporting on its performance
  • Research will be used to help the organisation to deal more effectively with issues of disparity
  • The SRA will have improved, accurate and updated data on the regulated community and informants.

Objective 7: accessibility and communication

We will provide accessible information and promote equality in the take up of support offered to the profession

Actions

Action Completion date Responsibility
7.1 Develop and implement a reasonable adjustments and alternative language protocol to deal with requests for reasonable adjustments from our stakeholders Jan 2009 Director of Policy (Inclusion)/all directors
7.2 Review the accessibility of our website and carry out an online survey of web users to build up a profile of those who use our website May and Sep 2009 Director of Policy and Communications
7.3 Promote the Ethics Helpline to the profession, including professional representative groups, small practices and sole practitioners, and monitor the take up of the helpline by equality strands Apr 2009 and ongoing Director of Standards
7.4 Work with key professional representative groups to raise awareness of the role of the SRA and responsibilities of the profession Dec 2008–Dec 2009 Director of Policy and Communications/ Director of Policy (Inclusion)
7.5 Work collaboratively with the Law Society to provide advice and guidance to sole practitioners and small firms, including advice on the Qualified Lawyer Transfer Regulations Aug 2009 Director of Policy and Communications/ Director of Policy (Inclusion)

Outcomes

  • Stakeholders will have improved access to the SRA's published policies, information and documents
  • The SRA will be seen as an organisation that is responsive to the needs of those who access its information and services.

Objective 8: consultation and involvement

We will engage and consult with the profession, consumers of legal services and the wider public on policy development and decision making

Actions

Action Completion date Responsibility
8.1 Develop and implement a consumer engagement policy to ensure engagement with all sections of the community Mar 2009 Director of Policy and Communications
8.2 Engage and consult with professional representative groups on impact assessments, guidance and information and policy development including the E&D strategy and action plan Feb 2009 and ongoing All Directors
8.3 Monitor our consultation and engagement activity Dec 2008–Dec 2010 Director of Policy and Communications/ Director of Policy (Inclusion)

Outcomes

  • The SRA will be demonstrably inclusive in the way it consults and involves its diverse stakeholders in informing its regulatory policy development and decision making.

Objective 9: promoting equality in the profession

We will consider how we can better promote equality in the profession

Actions

Action Completion date Responsibility
9.1 Consider options to improve compliance with Rule 6 Jun 2009 Director of Regulation Response
9.2 Publish annual reports on the complaints received in relation to Rule 6 breaches and work with the Law Society and the Legal Complaints Service to improve standards in the profession Jun 2009 and annually Director of Regulation Response/Director of Policy and Communications

Outcomes

  • Improved compliance and monitoring of Rule 6
  • Increased understanding and awareness of Rule 6 within the profession.

Objective 10: contracting and procurement

Embed E&D into procurement policy and procedure

Actions

Action Completion date Responsibility
10.1 Review and amend our procurement policy to ensure that E&D is integrated as a requirement in tenders and contracts May 2009 All directors/ procurement manager
10.2 Consider options, including positive action, to increase the diversity of the pool of suppliers who act on our behalf as intervention agents or adjudicators Feb 2009 and ongoing All directors and procurement manager

Outcomes

  • E&D will be embedded in the procurement policies.
  • E&D competencies and requirements will be integrated into tenders and service level agreements.
  • The SRA will have a diverse pool of suppliers who are providing a range of services on its behalf.

Equality impact assessment schedule 2009-2010

Policy and communications directorate

Initial equality impact assessment Completion date Responsibility
Communications strategy January 2009 Director of Policy and Communications
Web content and lay-out February 2009
SRA literature December 2009
Organisation of events December 2009
Internal communications December 2010
Press and media relations December 2009
Corporate framework for risk management and control February 2009
Committee recruitment March 2009
Adjudication panel, Board and Committee support November 2009
Initial equality impact assessment Completion date Responsibility
Procurement April 2009  
Code for referral to the SDT March 2009
Appointment of adjudicators August 2009

Change programme

Initial equality impact assessment Completion date Responsibility
Organisational design May 2009 Head of Operations Development
Decision making May 2009
IT system Post April 2009
Entity based regulation November 2010
Any other Change Programme projects December 2010

Policy (inclusion) directorate

Initial equality impact assessment Completion date Responsibility
Complaints handling February 2009 Director of Policy (Inclusion)
Restricted communication May 2009
Reasonable Adjustments Protocol May 2009
Equality and Diversity Strategy April 2009

Inspection and investigation directorate

Full equality impact assessment Completion date Responsibility
Practice Standards Unit function November 2009 Director of Inspection and Investigation
Forensic Investigation function December 2009

Information directorate

Initial equality impact assessment Completion date Responsibility
Route to registration, (pre-admission trainee processes) qualification and admissions March 2009 Director of Information
Character and suitability March 2009
Certificate of good standing and attestation April 2009
Post-qualification accreditation scheme June 2009
Renewal form section 12 (RFs12) August 2009
Waiver/dispensation requests October 2009
Criminal Records Bureau checks December 2009
Recognised body renewals and initial applications March 2010
Extracts from the roll and solicitors practising certificates May 2010
Registration of lawyers July 2010
Refunds policies August 2010
Findings and orders September 2010
Vetting requests December 2010

Client protection directorate

Initial equality impact assessment Completion date Responsibility
Claims management June 2009 Director of Client Protection
Financial protection August 2009
Cost recovery December 2009
Intervention August 2010
Technical Services December 2010

Regulation standards directorate

Initial equality impact assessment Completion date Responsibility
Higher rights of audience April 2009 Director of Regulation Standards
Legal Practice Course April 2009
Training contract inspection changes July 2009
Common framework (including authorisation and monitoring of course providers) implementation July 2009
Changes made by the Legal Services Act August 2009
Student enrolment September 2009
Qualified Lawyer Transfer Scheme September 2009
Work-based learning November 2009
Training Regulation waivers December 2009
Quality and Standards Framework December 2009
All rules within Code of Conduct February 2010
Case work and appeals processes for pre-admission decision making April 2010
Professional responsibilities test November 2010

Regulation response directorate

Initial equality impact assessment Completion date Responsibility
Matter based investigations February 2009 Director of Regulation Response
Excluded matter policy February 2009
Decisions to intervene April 2009
Section 43 policy appeals – deals with requests to work as an un-admitted person that had a section 43 Order placed against them July 2009
Section 41 policy appeals – deals with requests to work as an un-admitted person when they have been struck off, suspended or bankrupt previously October 2009
Intelligence gathering policies/processes (Fraud and Confidential Intelligence Bureau) March 2009
General applications March 2010
Administration processes March 2010

Full equality impact assessment Completion date Responsibility
Section 12 applications July 2009 Director of Regulation (Response)
Risk assessment – to include Designation Centre and Fraud and Confidential Intelligence Bureau June 2009