The Independent Complaints Reviewer

Race Equality Scheme

Mission Statement

The ICR will be fair and impartial in the review of complaints made by individual members of the public or organisations. Assistance and complaints review offered by the ICR team will be:

Independent and free of charge
Efficient and effective
Provided by a dedicated team who are committed to high and continuously improving standards
Flexible, so that it can change in response to the needs and preferences of our service users
Accessible and well publicised
Administered in accordance with the principles of public life and good administrative practice guidelines

Context

The Race Relations Amendment Act (RRAA) came into force in April 2001. It strengthens and adds to the existing provisions of the Race Relations Act 1976, placing a statutory duty on public authorities to have due regard to the need to eliminate unlawful racial discrimination and to promote good relations between persons of different racial groups.
The aim of placing the duty to promote race equality on all public authorities is to improve standards in the delivery of public services. The RRAA seeks to ensure that public sector services are provided fairly to everyone and that the public sector better reflects the society that it serves.
The RRAA imposes both general and specific duties on most public employers. Specific duties cover policy, service delivery and employment.
Specific policy/service delivery duties are:
To publish a race equality Scheme by 31 May 2002, stating:
- How we intend to meet our obligations under the general and specific duties;
- Which functions are assessed as relevant to the general duty;
- How we will assess and consult on the impact of our policies on race equality;
- How we will monitor for adverse impact;
- How we will publish the results of these assessments, consultation and monitoring;
- How we will ensure public access to information and services; and
- How we will train staff in relation to these duties.
Specific employment duties are:
- To monitor by ethnicity staff in post and applicants for jobs, promotion and training;
- To monitor by ethnicity and analyse grievances, disciplinary action, performance appraisal, dismissals and other reasons for leaving; and
- To publish annually the results of our ethnic monitoring, using existing systems where possible rather than creating new reporting mechanisms.

The Scheme

Section 1 - Meeting the General and Specific Duties

1.1 The ICR is committed to meeting its obligations under the RRAA and acting as a model of good practice in all areas of diversity. Our Managing Diversity Strategy is central to the delivery of our service and to the way we manage our staff.

1.2 Our Managing Diversity Strategy is reproduced at Annex A.

1.3 The ICR is partially funded by HM Land Registry and members of our staff are seconded from the Agency. Accordingly, we affirm our commitment to its Managing Diversity Strategy.

1.4 Customer Service Policy and Strategy

Our Statement of Service Standards is reproduced at Annex B.

1.5 The ICR will continue to use all existing systems and procedures and, where necessary, introduce new ones to eliminate unlawful discrimination and to promote equality of opportunity and good relations between persons of different racial groups.

Employment duties are dealt with under Section 8.

Section 2 - The ICR's General Approach to Meeting the General and Specific Statutory Duties

In this section, we set out the general approach we will adopt to meet the general and specific statutory duties.

General principles

The CRE Code of Practice states that four principles should govern public bodies' efforts to meet the general statutory duty:

The general statutory duty is obligatory. Public bodies must make race equality an integral part of planning, policy making, service delivery and employment. This is sometimes referred to as "mainstreaming" race equality. If race equality is relevant to its functions, a public body should do all it can to meet the general statutory duty.
Public bodies must meet the general statutory duty in all relevant functions. Race equality will be relevant to some public functions more than others. Public bodies should therefore assess whether, and how, race equality is relevant to each of their functions, and may decide that the general duty does not apply to some of its functions.

Under section 71(1) of the Act, we must have "due regard" to each part of the general statutory duty. This means that the weight given to race equality should be proportionate to its relevance. In practice, a proportionate approach may mean giving greater consideration and resources to those functions which could have most effect, and which could affect racial groups in different ways.

The elements of the general statutory duty are complementary, which means that all must be addressed in order to meet the whole general statutory duty. The general statutory duty has three parts:

Eliminating unlawful racial discrimination;
Promoting equality of opportunity between people of different racial groups; and
Promoting good relations between people of different racial groups.

These three parts support each other and may overlap. For example, promoting equality of opportunity may also eliminate or prevent unlawful racial discrimination and promote good race relations. However, it is important to consider and deal with all three parts of the general duty separately.

Our approach

The ICR has decided to set out how it will meet its general and specific statutory duties in a corporate Race Equality Scheme to ensure a consistent approach to race equality.

Section 3 - Assessing and Consulting

3.1 The Assessment Process

3.1.1 We are developing a policy screening template to monitor the impact of proposed policies on people of different racial groups. This process will take into account:

which functions involve or affect the public;
whether the inclusion of that function is proportionate to its potential impact on the public;
its impact or potential impact on members of ethnic minority communities.

3.1.2 Functions which are assessed as falling within this Scheme's criteria are:

Customer Service
Corporate Image
Employment Duties

The frequency of this review will be proportionate to the impact of the functions and policies on the public. Where the impact is significant, the review will take place on an annual basis; where not the review will be on a 3-yearly cycle.

3.2 Consultation

3.2.1 The ICR has made a commitment to bringing the policy making process closer to the people through consultation.

3.2.2 We actively seek feedback from all our customers.

We do this through our website, annual customer survey, and discussion group.

The discussion group meetings are held at least yearly. This ensures that we regularly meet with representatives from the Law Society, Council of Mortgage Lenders, The Agricultural Law Society and the Institute of Legal Executives.

Our publications provide an opportunity for customers to let us know if they would prefer to receive information in languages other than English. The responses to this will be analysed yearly.

Our staff have access, through one of our sponsoring Organisations, to a database of those members of staff who can speak a wide range of languages other than English to help with specific customer service needs. This database will be kept under review.

Section 4 - Monitoring Arrangements

4.1 The ICR intends that all its policies and services should be monitored for their impact on the public and in particular for any differential impact on particular groups within the general public. Where policies are found to have an adverse impact on a particular ethnic group those responsible for the policy will consider how to alter it so that the original objectives can be met without an adverse impact.

4.2 Monitoring as an intrinsic and regular feature of all ICR policies and services is currently being built in to the system. This includes the collection of statistical evidence disaggregated by race, gender, disability, age and, where necessary/ possible full or part-time working, and any other relevant factors. The statistics are analysed.

4.3 Our Senior Management Team is responsible for establishing systems that provide for equality monitoring data to be published annually in a comparative format, which is both easily understood and informs further policy development to take account of equal treatment

Section 5 - Publication

5.1 The assessment process referred to in 3.1 above can be published in a variety of formats to meet the needs of all groups. A copy of the policy screening template is at Annex C.

5.2 Monitoring results will be published using the existing methods for this purpose. Staff monitoring information will be published in an Annual Report.

Section 6 - Access to Information and Services

6.1 The ICR aims to provide information in a manner which is accessible to all.

6.2 Information is published externally through our website, press releases and various types of literature.

6.3 Mainstreaming diversity into all ICR publicity material is an important part of the publicity process. This is done by featuring positive images of, for example, ethnic minorities, men and women, in visual material and by reaching the varied ethnic and other groups within the community via dedicated communication routes.

Section 7 - Staff Training

7.1 The ICR is committed to ensuring that staff are trained properly so that they can make diversity issues core to their work, irrespective of where they work. Race equality is just one part of this.

7.2 We have developed a Managing Diversity and Valuing Inclusion Training event, which is mandatory for all senior managers. This is currently being provided to our Senior Management Team.

The objectives of the event are:

to give our key staff the knowledge to explain clearly the value of diversity to the team and to individuals in the team. This is especially important where there is confusion or resistance;
to develop self-awareness of their own qualities for harnessing the diversity of the people they work with;
to develop their skills for detecting the subtle indicators of underlying feelings and needs, so that they are more aware of communication issues for people of different backgrounds, cultures, needs and experiences;
to provide practical guidance in dealing with behaviours that seriously undermine morale and team synergy, particularly harassment, discriminatory behaviour and lack of mutual respect.

Further details are at Annex D.

7.3 A Cultural Diversity booklet is in the final stages of preparation providing guidance on religious and cultural observance, language and naming systems which will be made available to all staff.

Section 8 - Employment Duties

8.1 The ICR is committed to managing diversity and valuing inclusion in everything it does. Our aim is to truly reflect our local communities, where all are treated with dignity and respect of their individual contribution and where all are valued, supported and included so they can fulfil their potential. We monitor employment across all equality strands and in particular we monitor and analyse by ethnicity:

staff in post and applicants for jobs, training and promotion

Our approach to ethnic monitoring is to use the ethnic classification categories based on, or compatible with, that used in the 2001 Census.

Information on ethnicity is provided by staff voluntarily through ethnic monitoring forms completed by applicants joining the organisation.

A new survey, which complies with the Cabinet Office ethnic classification system introduced following the 2001 Census will be carried out in future using the same ethnic classification system.

We publish annually the results of our ethnic monitoring in our Annual Report.

The ICR is staffed through seconded individuals from our sponsoring organisations such as Land Registry. We commit ourselves to the aspirational targets for the proportion of ethnic minority staff in all grades, set by the Registry. The targets themselves and details of the framework for the Registry's target setting can be found at Annex E. These targets are kept under annual review.

8.2 We take action, where practicable, to address any adverse impact highlighted by the monitoring and analysis.

8.3 We seek staff feedback on our achievements in this area by means of reviews and team meetings.

Section 9 - Complaints Procedure

If you feel that you have been affected by a failure by the ICR to comply with its Race Equality Scheme, you should in the first instance contact the ICR's Diversity and Equality Officer. The address and telephone number can be found at the bottom of this page.

The Diversity and Equality Officer will acknowledge receipt of the complaint and will ensure that an internal investigation is carried out.

A substantive reply to the complaint will be provided in due course.

The Diversity and Equality Officer will maintain a register of complaints and will regularly review the complaints procedure to ensure that it is clear, open and fair.

You can contact the Equality and Diversity Officer at:

Equality and Diversity Officer
Independent Complaints Reviewer
New Premier House
150 Southampton Row
London
WC1B 5AL

Tel: 020 7278 6251

E-mail: icr@icrev.demon.co.uk

Annex A - The ICR's Commitment to Diversity

The Independent Complaints Reviewer is fully committed to treating people as individuals, providing equality of opportunity for all our employees and equal treatment for our customers.

We will operate all our policies towards our people, and will deliver our customer services, fairly, reasonably and without prejudice.

Valuing diversity will enable us to realise the full potential of all our employees and help provide the best possible service to all our customers.

We will:

ensure that all employees are aware of the ICR's policy on managing diversity and take appropriate action to improve knowledge and understanding. We will deal with any instances where our commitment to diversity has been undermined;
ensure that, as a minimum, our standards reflect the requirements of the law and any associated Codes of Practice and that we learn from best practice outside;
ensure that opportunities for recruitment, selection, job allocation, training and development, and promotion are available to all and ensure that our performance management and appraisal systems are fair, objective, and free from bias and stereotyping;
establish and promote an environment free from harassment, bullying, discrimination and victimisation and ensure that understanding of these issues is integral to the organisation's culture;
Seek to employ a workforce that reflects the diversity of local communities and society as a whole, which values and respects the individual and provides all customers with a service that is fair and meets their diverse needs;
Regularly monitor ourselves against, challenging diversity-based targets to maintain progress and, wherever possible, to actively address areas of weakness.

Annex B - Our Standards

Listening to you

We recognise the importance of seeking the views of complainants and their advisors, sponsoring organisations and others and responding positively to such feedback.

Customer feedback helps us to fulfil our commitment to giving a service that meets our customers' needs and to continuously improve our level of service and performance targets. We:

conduct an annual customer satisfaction survey
hold regular meetings with representative groups and customers
pay attention to comments, suggestions and complaints.

If you have any comments and suggestions to make about our service, please address them to the Office Manager.

We also encourage our staff to put forward ideas for improvement.

Value for money

The ICR is funded through contributions from our sponsoring organisations: HM Land Registry, the Charity Commission, National Archives, the Housing Corporation and Land Registers Northern Ireland. Our service is free to complainants.

Quality

The ICR is committed to ensuring that the level of service we provide remains at a high level and that every opportunity is taken to improve it. We have established internal audit mechanisms for monitoring and reviewing our work

Speed of Service

The ICR recognises the importance of timeliness in dealing with customer's complaints and is committed to handling every complaint as quickly as possible. We take into consideration that any unnecessary delay can add further inconvenience and stress for a complainant. It is therefore very important to see that the review process is as efficient and as speedy as possible, whilst always ensuring that these considerations do not compromise the quality of the review.

Our procedures and time objectives are designed to facilitate a prompt and effective complaints review service.

Annex C - Managing Diversity - Race Relations (Amendment) Act 2000

Policy Screening Template

A printable version of this document can be found here. If you have any difficulty in viewing this form, please contact us.

Annex D - Diversity in the ICR

Creating a Climate of Dignity and Respect for Everyone

A One-Day Programme for the Senior Management Team

If you want to get the best from diversity, you need to be able to articulate clearly and simply what is meant by diversity. You need to know the benefits, and what needs to be done differently to gain those benefits and avoid the pitfalls.

Demonstrating team leadership is essential for managers in today's fast changing world. Sometimes, teamwork is given so much importance that it tips over into groupthink. This is where full agreement is so important that alternatives are dismissed without being appraised, leading to flawed decision making.

To avoid groupthink, we need to embrace and manage diversity.

The objectives of the programme are shown in Section 7 of this Scheme.

Introductions
Equal opportunities, diversity, and positive action - similarities and differences
The benefits of diversity
Diversity leadership - assessing our capabilities
Understanding the basis of our attitudes - the cultural and attitudinal filters which affect our actions

'Live' situations - testing our assumptions about diversity in the workplace
Communicating mutual respect and influence and overcoming groupthink
Analysing the gaps between the current reality and the desired future and how to bridge those gaps
First steps for positive change

Annex E - Diversity Targets

1. Senior Civil Service Targets

Representation of ethnic minority staff in the SCS

At the end of 2001-02, ethnic minorities comprised 3% of SCS staff in Land Registry. Our target for 2010 is to have 5% of our SCS staff from ethnic minorities to better reflect the population as a whole.

2. Framework for targets below the SCS

The majority of our staff are at clerical and executive levels and are employed on registration work for which skills and knowledge are unique to the Registry. Over recent years, there has been progress in increasing the diversity within these groups and this is reflected in those now coming through to more senior levels.

Developments in technology and increased demand for our services are likely to continue to shape the Land Registry's staffing profile. The 21st century will bring new approaches to conveyancing, with increasing electronic delivery of service and this will have a significant impact on the make up of our workforce. With the potential for some reduction in staff numbers and a total staff turnover of between 3 and 4%, recruitment activity is likely to be comparatively low. It follows that we will need to focus strongly on existing personnel as we pursue our diversity strategy.

Human Resource policies will continue to encourage staff from all groups to put themselves forward for advancement. This will help us to meet the targets for staff below SCS as outlined in our framework.

For the framework, we will use the following grade bands:

Group A - RA and RO (equating approximately to AA and AO)
Group B - RE2L and RE2U (EO and HEO)
Group C - RE1 and SRE (SEO+)
Group D - SRAL, SRA2 and SRA1 (UG7 legal, UG7 & 6)

Targets below the SCS

Representation of ethnic minority staff below the SCS

We will be working with individual offices to set local targets based on their local population mix following completion of an equality proofing exercise on our recruitment process. New targets will be set in the light of this review.

At the end of 2001-02, ethnic minority staff comprised 7% of Group A, 3% of Group B, 1% of Group C and 2% of Group D. In total, ethnic minority staff comprised 4.5% of the workforce. The target for 2005 is for 5% of Group B and 3% of Groups C and D to be from ethnic minorities and by 2010 to increase this to 5% for Groups C and D.