Coalition for Racial Equality and Rights - anti-racist policy making: review

Identifying solutions: the challenges

Evidence to establish the racial inequalities that need to be tackled is, by and large, available to policy makers (provided they know where to look and how to interpret it). As previously mentioned, these inequalities have not changed a great deal over time, but a more challenging aspect of policy making is gathering the evidence on what works to create change in these inequalities. Work on race equality, whether in terms of national policy or local interventions, is notoriously under-evaluated. This means that policy makers are often setting actions without the ability to firmly assert that the actions will make a difference.

Whilst acknowledging this difficulty, there is a need to establish a clear link between race equality strategies' objectives and the most effective mechanisms for delivering them.

Practice over the years has not always reflected this well. Instead of developing specific, race-focussed mechanisms to create change, there is a tendency for policy makers to 'bolt on' race equality to current priorities and policy drivers, sometimes not specifying any action beyond considering race in these areas.

Mainstreaming is a key aspect of race equality work, and no reasonable argument can be made for approaches to race equality work that are divorced from the wider policy arena, but the key question must always be how to mainstream effectively.

Care has to be taken to ensure that race equality is addressed in the most robust way possible, through both targeted and mainstream policy. An example of how attempts to link targeted and mainstream policy can fail can be seen in the link between the Race Equality Framework for Scotland 2016-2030 and the Fairer Scotland Action Plan (Scottish Government's anti-poverty strategy), published six months later in October 2016.

In cognisance of the Fairer Scotland agenda, the Race Equality Framework contained a commitment to reflect its evidence base on race and poverty within the Fairer Scotland Action Plan. As poverty rates are twice as high in minority ethnic communities, this is a vital policy area. Nevertheless, a deliberate decision was made not to pre-empt the anti-poverty work by developing a larger range of commitments on tackling poverty within the Framework.

However, rather than building in actions relating to race equality as expected, the Fairer Scotland Action Plan simply committed to implementing the Race Equality Framework. A crucial moment to create synergy between the two policy areas was lost. Instead, the two conflicting commitments effectively cancelled each other out.

The key to avoiding missed opportunities or making ineffective proposals is to specify the inequality to be addressed, identify reasonable assumptions about what will work to address it, begin to develop appropriate actions and identify with certainty where these fit into the policy landscape without hesitation.

To set the best actions in this way, logic modelling could easily be employed when setting actions for race equality strategies.^[163] As set out by What Works Scotland, effective policy making processes "Navigate a path through complexity with a robust and explicit theory of change."^[164] Logic modelling is a useful tool for conducting this navigation.

Whatever the model for developing actions, it's imperative that these are sense-checked by people with knowledge of race equality. Stakeholder involvement can be one way of achieving this, however internal staff networks and advisory groups can also be called upon.

Views gathered through involvement, however, need to be interpreted with a clear understanding of anti-racist practice in order to result in meaningful solutions. An earlier review of race equality policy, conducted in 2005,^[165] found that "Scotland lacked a shared vision on race equality. There was a lack of a clear theoretical basis for race equality work and an absence of shared understanding of the issues, definitions, principles and nature of racism and race equality."

This was echoed in the aforementioned research conducted by Professor Nasar Meer on the 'Scottish approach' to race equality. It found that lack of consensus on the underlying cause of racial inequality was a barrier to effective policy making, and that this could only be addressed by building civil servants' capacity on race and tackling reticence to openly speak about structural racism alongside wider mobilisation.^[166]

This demonstrates that capacity building amongst policy makers on race equality (which appears to have been higher on the agenda in the early years of devolution) remains important.

The same research project also found that policy makers were not making the best use of evidence gathered from stakeholders because of the widely varying 'asks' put forward by race equality organisations and activists, in comparison to the smaller number of clear demands made by other parts of the equality sector such as women's and LGBT+ organisations.

There are valid reasons for the large number of different demands on race equality; there are a large number of different inequalities across different spheres of life, which have persisted over time without being tackled. It is arguably unreasonable to expect race equality stakeholders to agree to focus on a small number of goals.

An additional challenge, however, is that the problem of consensus on the underlying causes of racial inequality persists amongst stakeholders as well as within Government. During consultation on the Race Equality Framework for Scotland, some consultees from white minority ethnic groups put forward views about non-white minority ethnic groups which were firmly based on racial stereotypes, for example that overcrowding, lack of participation in civic life or employment were a result of 'cultural choices' and/or failure to learn to speak English.

Occasionally, people from non-white minority ethnic groups will also contribute views that are unwittingly based on racial stereotypes or are coded to avoid talking directly about racism. For example, minority ethnic women consulted about access to employment will often state that language barriers are a problem, but on further discussion it becomes clear that employers' perception of language barriers (i.e. a heavy accent being interpreted as lack of English language proficiency) is the real issue.^[167] The tendency to look for explanations for racial inequality within the actions and attitudes of minority ethnic groups is sometimes called the 'deficit model' of race equality.

The prevalence of the deficit model in discussions about solutions to racial inequality not only replicates racial stereotypes, but results in continual investment in capacity building activities for minority ethnic people which only have an impact on the a small minority of people who have capacity building needs. This is inefficient and reduces the amount of investment available to address social and structural racism.

Civil servants should be receptive to input from stakeholders, but need to have the capacity to assess which 'asks' should be prioritised for action in light of the severity of inequality and the extent to which action by Government might reduce it.

Leadership at all levels is necessary to enable this; civil servants operate within a hierarchical environment where certainty on priorities and ethos is needed to enable anti-racist policy making. An open letter signed by 88 academics, trade unionists, campaigners and race equality organisations in 2019 raised concerns that attitudes to race and racism were rolling backwards in Scotland.

Although the letter was not exclusively focussed on the policy making environment, it stressed that "Within public sector work on race equality, we see a worrying trend towards limiting understanding of race to its basic legal definition. Everyone in Scotland is protected by law from racial discrimination on the grounds of their colour, nationality and ethnic or national origins, as is fair and just. However, it is blatantly unfair to suggest that the risk of inequality and discrimination on the grounds of race is equally applicable to everyone in Scotland."^[168]

A real-life example of the consequences of blanket approaches to race equality can be seen in the positive action programme carried out by one of Scotland's national agencies. After considerable investment in this programme, the results were deemed to be a great success. However, a disproportionate number of those completing the programme and moving into work were from various white minority ethnic backgrounds for whom no evidence of barriers to entry had been gathered. BME people did not benefit from the programme in the way intended, and were still disadvantaged despite the high level of investment. Replicating this type of approach, rather than taking evidence based, anti-racist action, is an inefficient use of resource and could actively widen gaps if disproportionate numbers of people who do not face barriers benefit.

Confidence to assert evidence based policy decisions, even where this may result in taking on board some stakeholder views and not others, is a vital missing link in much race equality policy development. Building policy makers' capacity on race equality, to aid interpretation of the evidence, would help to address this.^[169]

Not all capacity building opportunities, however, are equally valuable. The Race Equality Advisory Forum's 2001 recommendations stated that "To be effective race equality training must be: an integral part of the training programme of every part of the public sector; compulsory as opposed to voluntary or optional; authoritative, constructive, informative and relevant; based upon clear standards for content and delivery; and anti-racist."^[170]

More recently, CRER has developed a set of principles for quality assuring race equality training from an anti-racist perspective as part of work to support the implementation of the Race Equality Action Plan 2017-2021.^[171] The quality of capacity building on race equality can make or break an organisation's ability to take effective action.^[172]

As set out in the section on overarching issues, capacity building on race equality has been one of the most recurring themes across twenty years of race equality policy. Attempts were made to address training needs through the creation of the National Equal Opportunity Training in Scotland (NEOTS), which arose out of the Scottish Executive's Stephen Lawrence Working Group. This group was convened to address the need for joined-up and coherent approaches to race equality training in the public sector, most particularly in the justice sector.

This need is still evident, and with several commitments to sector-specific and general capacity building on race equality lying within the Race Equality Framework for Scotland 2016-2030, there are opportunities to address it.

Crucially, however, capacity building cannot be confined to a small number of race equality champions. Allyship between civil servants with a dedicated interest in race equality and race equality stakeholders has arguably been the driving force in maintaining the race equality agenda within Scottish Government. The challenge is that these allies are often isolated and lack the reach, power and influence to sustain progress within that agenda.^[173]

Capacity building therefore needs to embed race equality and anti-racist principles in the day to day work of civil servants across the board. This is recognised within the current Race Recruitment and Retention Plan, in which 'Building an anti-racist culture' is one of five key priorities.^[174]

Capacity building is only one part of the picture, however. In order to create realistic solutions, actions need to be practical, designed in collaboration with those involved in implementing them and agreed by those with leadership responsibilities. In several previous cases, actions have been determined which cannot be implemented due to differences between the expectation of what could be achieved and the reality of what can be achieved. Prior engagement and agreement could have avoided this.

Solutions also need to be focussed on creating meaningful change in the lives of people impacted by racism and racial inequalities. A focus on outcomes has been positioned as vitally important to policy making in Scotland, especially following the Christie Commission's report in 2001.^[175]

However, the benefits of the outcomes based approach have not always been realised in policy making on race equality. Where this approach is evident (for example, in the visions and goals of the Race Equality Framework for Scotland), mechanisms for reporting on outcomes are missing. Without progress measurement, race equality outcomes become simply ambitions rather than changes to be achieved in the lives of minority ethnic people.

A 2017 report on the use of evidence in policy making by the Carnegie Trust highlighted the disconnect between outcomes and indicators: "The particular focus on outcomes in Scotland has a clear implication for evidence, in that outcomes ask the question: is the policy or programme making a difference to individuals and communities in the round? This is in contrast to the typical basket of indicators for social programmes and projects, which focus on input or outputs, such as how many police are patrolling the streets, or how many training or skills courses a job seeker has attended."^[176]

To assist in identifying solutions, Scottish Government may wish to consider:

• High quality capacity building on race equality for policy makers, with a particular focus on how to interpret and prioritise evidence from an anti-racist perspective
• Policy planning processes which begin with the desired outcome and work backwards to identify viable, meaningful, measurable actions
• Requiring all race equality actions to be agreed with the relevant policy area and formally 'signed off' by a named person at an appropriate level of seniority before publication, linking this to implementation and progress reporting