As a Registered Social Landlord (RSL) in Scotland, West Granton Housing Co-operative (WGHC) is regulated by the Scottish Housing Regulator (SHR). The SHR require all RSLs in Scotland to collect equality data. There are nine ‘protected characteristics’ defined under the Equality Act 2010. Of the nine, eight also constitute ‘special category data’ as defined within the UK General Data Protection Regulation ( UK GDPR) and the Data Protection Act 2018. The legislation makes it clear as to how and why this data might be collected and used.
The SHR require RSLs to collect equality data for:
- New Tenants
- Existing Tenants
- People on Waiting Lists
- Governing Body Members
- Staff (including job applicants)
WGHC have been developing a comprehensive equality strategy since 2020 which we began implementing from April 2022. As well as a new equality policy and equality action plan, we have developed other detailed procedures to ensure effective equality impact assessments of organisational services. An equality impact assessment involves assessing our policies, procedures and related documentation so that they comply with equality law and associated guidance.
One very important procedure that we have been developing is our equality data collection procedure. This is the procedure that we would like to explain so you are aware of present developments.
Equality data collection procedure
The following sections explain the following issues:
- regulatory context;
- our staff procedures;
- new equality data collection forms;
- starting to collect equality data; and
- implications for tenants.
The Scottish Housing Regulator requires social landlords in Scotland to collect equality data as part of their commitment to mainstream equality objectives throughout organisational services. The data that we are required to collect relates to the protected characteristics as defined in the Equality Act 2010. We are to collect equality data for several groups; one of the groups covers our tenants.
Our staff procedures
Our staff will be collecting equality data in line with our new equality data collection procedures. You should note that these procedures are regulated by our data protection processes.
This means that we:
- only collect equality data if we are entitled to do so;
- process data securely and confidentially, as appropriate;
- restrict access to equality data*;
- only collect data if we have clear reasons or purposes for doing so;
- update information in ways agreed with you; and;
- destroy such data in line with our data retention schedule.
* Only staff who need to know this information in support of their employed function within WGHC will have access to your information.
New equality data collection forms
We have also developed a new equality data collection form that tenants, governing body members and staff will be asked to complete. Although you only need to complete this form if you want to, it is stressed that information that we gather is used to promote your interests. Examples of this are given below.
Example 1: Knowing whether or not you are a disabled person. By letting us know if you are a disabled person and advising us of your needs, we can adjust our services to address your particular requirements. In law, this is known as making reasonable adjustments; failure to make such adjustments can constitute unlawful discrimination.
Example 2: Knowing your ethnicity. By telling us about your ethnicity and related needs, we can ensure providing you with appropriate services, for example, arranging interpreters for Polish tenants who do not speak English.
Example 3: Knowing your belief or religion. By letting us know your beliefs and needs, we can ensure that we do not discriminate in service provision. For instance, we would avoid holding meetings with you on dates notified to us as religious holidays.
Starting to collect equality data
We intend to pilot using the new equality data collection from April 2022 onwards after:
- providing staff training; and
- testing the form (“a pilot project”).
Implications for tenants
By participating in this equality data collection process, you will be supporting us to develop a data base that might assist WGHC with choices for service provision, when meetings might be held etc. This data base will support us, not only to provide services tailored to your needs, but also to promote the Public Sector Equality Duty. As well as promoting equality objectives, the Duty requires us, when providing services, to eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act.
Our new equality strategy has been developed to ensure that equality law and guidance is incorporated throughout all organisational services. An important aspect of the strategy is to collect equality data from tenants. We will use this information, not simply to ensure compliance with law and regulatory provisions, but to tailor housing services to the needs of tenants, where this is relevant and/or practical.
Should you have any particular questions about our equality strategy, or you would like a new form, please contact us on 0131 551 5035 or firstname.lastname@example.org