Homeless Persons (Unsuitable Accommodation) (Scotland) Amendment (No.2) Order 2020: equality impact assessment

This amendment to the 2014 Unsuitable Accommodation Order seeks to amend some of the Articles within the 2020/139 Order laid in May 2020 and to clarify terms and definitions of suitability of accommodation and when exemptions should apply.


Stage 2: Data and evidence gathering, involvement and consultation

Include here the results of your evidence gathering (including framing exercise), including qualitative and quantitative data and the source of that information, whether national statistics, surveys or consultations with relevant equality groups.

Characteristic[1]

Evidence gathered and

Strength/quality of evidence

Source

Data gaps identified and action taken

Age

At 31 March 2020 there were 11,665 households in temporary accommodation.

Average number of days spent in temporary accommodation ranged from:

Highest - aged between 35 and 49 – 200 days

Lowest - aged 65 and over – 133 days

In 2019/20 the UAO limiting the amount of time households with pregnant women or children can be placed in unsuitable accommodation to 7 days was breached 495 times compared to 645 in 2018/19.

395 of the 495 breaches were for the age group 25-49.

Scottish Government HL1 statistics.

Data availability around age is strong.

Disability

Scottish Government does not collect data regarding disabilities from people placed in B&B for more than seven days.

No evidence gathered.

No comprehensive and accurate data is available.

Since we do not gather data we are not yet sure of the direct/indirect impact of this policy on this characteristic.

However, we aim to keep it under review and work with analysts to change the information captured by the housing/homelessness returns by local authorities to look to include data on the characteristics that are absent at the moment but when included will provide a clearer picture on how they are affected and represented in the homelessness sector and ensure we have considered disabled people's needs fully.

We will seek to engage with organisations representing disabled people to establish what their concerns are, and will then use that information to review and revise our policy as necessary, with this stakeholder intelligence sitting alongside information developed by analysts.

Sex

Of the 11,665 households in TA at 31 March 2020

The average number of days spent in temporary accommodation:

87 – single male;

108 – single male parent;

85 – single female;

131 – single female parent

In 2019/20 out of the 8825 placements where B&B was used:

55% = single males;

19% = single females;

2% = single male parent;

11% = single female parent;

The remaining 13% relates to couples and couples with children.

Scottish Government HL1 statistics.

Data availability around sex is strong.

Pregnancy And Maternity

In 2019/20 the Unsuitable Accommodation Order limiting the amount of time households with pregnant women or children can be placed in unsuitable accommodation to seven days was breached 495 times.

Of those experiencing breaches -

2% - single pregnant woman;

3% - couple with pregnant woman;

5% - single male parent;

49% - single female parent;

31% - couple with children;

10% - other with children.

Other is likely to include formal or informal kinship care arrangements, such as children living with older siblings or grandparents.

Scottish Government HL1 statistics.

Data availability is strong for this characteristic.

Gender Reassignment

Scottish Government does not collect data regarding the gender reassignment status of people placed in B&B for more than seven days.

The Registrar General for Scotland maintains a Gender Recognition Register in which the birth of a transgender person whose acquired gender has been legally recognised is registered showing any new name(s) and the acquired gender. This enables the transgender person to apply to the Registrar General for Scotland for a new birth certificate showing the new name(s) and the acquired gender. In 2014, there were 16 entries in the Gender Recognition Register, the same number as in 2013. The Gender Recognition Register is not open to public scrutiny.

No evidence gathered.

No comprehensive and accurate data is available.

At the moment we do not gather data on this characteristic and so we are not yet sure of the direct/indirect impact of this policy on this characteristic.

We do aim to keep it under review and work with analysts to change the information captured by the housing/homelessness returns by local authorities to look to include data on the characteristics that are absent at the moment but when included will provide a better view on how they are affected and represented in the homelessness sector and ensure we have considered this characteristic fully.

We will seek to engage with organisations representing this characteristic to establish what their concerns are, and will then use that information to review and revise our policy as necessary, with this stakeholder intelligence sitting alongside information developed by analysts.

Sexual Orientation

Scottish Government does not collect data regarding the sexual orientation of people placed in B&B for more than seven days.

No evidence gathered.

No comprehensive and accurate data is available.

At the moment we do not gather data on this characteristic and so we are unable to determine what the direct/indirect impact of this policy may be on this characteristic.

We do aim to keep it under review and work with analysts to change the information captured by the housing/homelessness returns by local authorities to look to include data on the characteristics that are absent at the moment but when included will provide a better view on how they are affected and represented in the homelessness sector and ensure we have considered this characteristic fully.

We will seek to engage with organisations representing this characteristic to establish what their concerns are, and will then use that information to review and revise our policy as necessary, with this stakeholder intelligence sitting alongside information developed by analysts.

Race

In 2019/20 out of the 8825 placements where B&B was used there were:

80% = White;

3% = African;

1% = Caribbean or Black;

2% = Asian, Asian Scottish or Asian British;

1% = mixed or multiple ethnic groups;

8% = other ethnic group;

5% = not known or refused

In 2019/20 out of the 495 placements where B&B was used for more than seven days there were:

56% = White;

13% = African;

4% = Caribbean or Black;

7% = Asian, Asian Scottish or Asian British;

3% = mixed or multiple ethnic groups;

14% = other ethnic group;

3% = not known or refused;

Scottish Government HL1 statistics

By comparison 96% of the Scottish population are of white ethnicity.

Religion Or Belief

Scottish Government does not collect data regarding the religion or beliefs held by people placed in B&B for more than seven days.

No evidence gathered.

No comprehensive and accurate data is available.

Currently we do not gather data on this characteristic and so we are unable to determine what the direct/indirect impact of this policy may be on this characteristic.

We do aim to keep it under review and work with analysts to change the information captured by the housing/homelessness returns by local authorities to look to include data on the characteristics that are absent at the moment but when included will provide a better view on how they are affected and represented in the homelessness sector and ensure we have considered this characteristic fully.

We will seek to engage with organisations representing this characteristic to establish what their concerns are, and will then use that information to review and revise our policy as necessary, with this stakeholder intelligence sitting alongside information developed by analysts.

Marriage And Civil Partnership

(the Scottish Government does not require assessment against this protected characteristic unless the policy or practice relates to work, for example HR policies and practices - refer to Definitions of Protected Characteristics document for details)

Scottish Government does not collect data regarding the marriage or civil partnership status of people placed in B&B for more than seven days.

No evidence gathered.

No comprehensive and accurate data is available.

At the moment we do not gather data on this characteristic and so we are unable to determine what the direct/indirect impact of this policy may be on this characteristic.

We aim to keep it under review and work with analysts to change the information captured by the housing/homelessness returns by local authorities to look to include data on the characteristics that are absent at the moment but when included will provide a better view on how they are affected and represented in the homelessness sector and ensure we have considered this characteristic fully.

We will seek to engage with organisations representing this characteristic to establish what their concerns are, and will then use that information to review and revise our policy as necessary, with this stakeholder intelligence sitting alongside information developed by analysts.

Contact

Email: Homelessness_External_Mail@gov.scot

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