Race equality action plan: final report

Progress made on the actions in the Race Equality Action Plan 2017 to 2021 and action taken to tackle race inequality in response to the 2020 to 2021 COVID-19 pandemic as well as action from 2021 onwards to implement the aims of the Race Equality Framework 2016-2030.

Annex D – Housing

These annexes provide updates on all original actions from the Race Equality Action Plan followed by updates on the reprioritised and refocused actions from the end of Year 2. Additional activity in Year 3 that has taken place in response to either COVID-19 or Black Lives Matter is then captured.

Action status categorisation is as follows

  • Complete*
  • Ongoing**
  • Paused
  • Reprioritised

*We cannot see this work as being done just because an action has been completed within a timeframe. For some actions, the marking of a status as complete may mean that the specific one-off action as originally proposed has been undertaken however work continues in this area and this is reflected in the update.

** Actions may be marked as 'ongoing' for the same reason. Much of the work reflected in these annexes is long-term in nature and continues beyond the end of the REAP.

Year 1 only
Action Action Status Update
The Centre for Housing Market Analysis (CHMA) will update the Housing Need and Demand Assessment (HNDA) Tool and associated data by the end of 2017, and the tool will be supported by refreshed guidance. The refreshed guidance will include updates to areas that have generated consistent comments during the Robust and Credible appraisal process. Complete The latest Housing Need and Demand Assessment refreshed guidance was published in November 2020 and this includes the consideration of any housing issues for protected characteristics. Housing and Demand Assessment Guidance
Consideration will be given to making Consultation one of the Robust and Credible criteria on which the HNDA assessment is based, to ensure clarity around who has been consulted, how they were consulted and the findings from the feedback received. This should help to ensure that the evidence base for the HNDA is more informed and reflects more accurately the current and future need for housing and housing related services for all, including minority ethnic communities. Complete The HNDA Refresh was published in November 2020. The Scottish Government formal appraisal criteria now require authorities to consult with relevant stakeholders about their housing needs.
Working through the Private Rented Sector Investigations and Prosecutions Working Group, we will develop guidance to enable more effective enforcement and prosecution in the Private Rented Sector by March 2018. Complete We worked in partnership with Police Scotland, the Crown Office and Prosecutions Service, the Housing & Property Chamber of the First-tier Tribunal and Local Authorities to develop the guidance and identify practical solutions to the issues that were highlighted around effective enforcement and prosecution. The purpose of the guidance is to support better understanding across all agencies of the Private Rented Sector of the role that different bodies have in ensuring compliance by landlords with their legislative duties. The Guidance was published at the end of August 2018.
Over the next twelve months we will identify and promote a wide range of measures to encourage and support the sharing of good practice across the sector to improve standards, and between local authorities in their enforcement role. We will identify good practice by local authorities in supporting minority ethnic landlords to understand their obligations and in providing minority ethnic tenants with information about their rights and share this more widely by supplementing the existing guidance. Complete The Scottish Government funded a Private Landlord Support Officer post in Glasgow City Council for a year following the success of the Shelter project with Dundee City Council. The positive impact of the work led both local authorities to make these posts permanent. The PLSOs work with landlords in their city to promote greater compliance with legal responsibilities. We will work with them to identify good practice and promote this through the national Landlord Registration Network. A review of the landlord registration statutory guidance for local authorities is underway. We will liaise with local authorities (including PLSOs) and other stakeholders to update existing content relating to race equality and share the updated guidance with the National Landlord Registration Network. The impact of the ongoing pandemic has meant that local authorities and Scottish Government work has been focused on the response to the health emergency and priority work, this has led to delays in the ongoing review. The Scottish Government intends to undertake further collaborative work with local authorities in the coming months, to assess the effectiveness of the current guidance and to update it.
We will develop and implement a framework for gathering information to monitor the impact of new legislative changes on those living in the Private Rented Sector, including the impact on minority ethnic private tenants. Ongoing As part of the Scottish Parliament Information Centre (SPICe) academic engagement programme with the Urban Big Data Centre (UBDC) at the University of Glasgow and the UK Collaborative Centre for Housing Evidence (CaCHE), two briefings were produced on private renting reforms in Nov 2018[4] and 2019[5]. The Nationwide Foundation funded a 3 year Private Rent Sector research programme called Rent Better. A full set of baseline findings were published in November 2020 that includes some analysis of impacts on tenants from minority ethnic groups. The Scottish Government is designing a framework to complement and build upon this work and will include a focus on how the changes brought in by the new Private Residential Tenancy have impacted on minority ethnic tenantsThe framework is currently in draft form and will be finalised later in 2021. We will review what further research is needed in light of Housing Needs of Minority Ethnic Groups evidence review[6] findings and gaps in the Rent Better research. Rent Better Baseline Full Report
Year 2 only
Action Action Status Update
We will review Local Housing Strategy (LHS) guidance in 2018-19 and this will be used to address areas of concern highlighted by the review process so far and other issues that have arisen since the guidance was last updated in August 2014. The guidance will also reflect all changes coming from the HNDA refresh and the planning review, as well as a range of other new or amended policies that impact on housing. Complete Revised Local Housing Strategy guidance is being used by Local Authorities in the development of their forthcoming Local Housing Strategies, supported by updated Housing Need and Demand Assessment Guidance. The revised guidance (2019) makes clear the expectation that local authorities should engage with and consider any needs of minority ethnic communities that are additional to those covered by mainstream housing including for homes suitable for larger/extended family groups and /or any other specific cultural needs. 'Accommodation Actions' under the Gypsy Traveller Action Plan, which was published in October 2019, include an action on identifying and understanding Gypsy/Traveller accommodation needs. "The Scottish Government will work with COSLA and stakeholders to consider whether further quantitative/qualitative data would add value and impact to policy making and practice at a regional and/or a national level and how this can best be achieved." This action is being progressed with the More and Better Gypsy/Traveller Accommodation Stakeholder Group. Work on this was delayed due to COVID 19 but we are now considering alternative options for undertaking research.
We will reaffirm in the Housing Need and Demand Assessment and LHS guidance the expectation that local authorities fully consider the requirement for larger accommodation, including for minority ethnic families and seek to address any identified need. The HNDA guidance is being refreshed now and the LHS guidance is to be refreshed 2018-19. The review process for the LHS will take this requirement into account when providing feedback to local authorities. Complete The latest HNDA Guidance (November 2020) asks authorities to consider what sizes of properties are needed across their housing stock. Revised Local Housing Strategy guidance is being used by Local Authorities in the development of their forthcoming Local Housing Strategies, supported by updated Housing Need and Demand Assessment Guidance. Local Authorities are expected to reflect any identified priorities relating to larger homes or for minority ethnic families through their Strategic Housing Investment Plans which are reviewed by the Scottish Government.
We will carry out a scoping exercise which would allow a clearer picture to be established of what research is required on the housing needs and experiences of minority ethnic households. Complete A review of evidence on the housing needs of minority ethnic groups was published in January 2021: Housing Needs of Minority Ethnic Groups Evidence Review The report provides a review of the literature on the housing needs and experiences of minority ethnic groups in Scotland, and presents results of secondary data analysis from the Scottish Household Survey and Scottish House Condition Survey. A meeting to discuss the findings and possible next steps took place on 25 January 2021 and SG officials will use this analysis to inform the development and implementation of Housing to 2040, which was published on 56 March 2021. An overview of evidence about the accommodation needs of Gypsy/Travellers in Scotland, drawing on both academic and grey literature, was published in October 2020: Evidence Review of Accommodation Needs for Gypsy Traveller community
We will ensure that the Joint Housing Policy and Delivery Group has a renewed focus on the specific needs of minority ethnic communities. We will recommend to the Group that an additional outcome is added to the Joint Housing Delivery Plan for Scotland so that it is explicit that our working groups should take account of the specific needs of minority ethnic communities. We will recommend to the Group that the specific needs of minority ethnic communities are considered as a strategic discussion item at their plenary in 2018. Complete A race equality outcome for Joint Housing Policy and Delivery Group (JHPDG) was included in the annual report (published in July 2019). The draft outcome is 'a collaborative and joint approach to improving diversity in housing, which leads to better delivery for minority ethnic communities, and more diverse recruitment in the housing sector'. A commitment was made by members of JHPDG to support action to tackle race inequality in housing - this was interrupted by COVID when all Group activity was suspended but will be added to the agenda at any future meeting. Scottish Government held an event on race equality in housing in 2020, enabling housing professionals to hear real life experience from people from minority ethnic communities, and provide learning. Meeting the needs of people from minority ethnic groups will be part of our work to develop governance structures and processes to deliver H2040.
We are working with Homes for Scotland, to develop better baseline information about skillsets, industry demographics, population representation levels, including for minority ethnic individuals and current and future skills requirements in industry over the coming year. Paused Work on skills capacity within the sector was paused due to the COVID-19 pandemic. We will carefully consider the recommendations of the Social Renewal Advisory Board, established during the COVID-19 pandemic and which has an emphasis on delivering equality and social justice. The SRAB report on employment in housing/construction recommends that: Each employability or skills programme/funding stream should be required to set out what action it will take to ensure that people from minority ethnic groups, refugees, disabled people, women, single parents, young people, older people, carers and people from deprived areas benefit from what it offers (action 4.1). This will be taken forward in the context of Scotland's recently published new 20 year housing strategy, Housing to 2040.
This baseline information will allow us to identify skills needs and gain a better understanding of current representation levels. We will then work together and with relevant skills providers to promote industry participation and opportunities in the industry's many roles and professionalisms to targeting specific demographics, including younger people, across traditional industry gender divides and minority ethnic communities. Paused The above update applies here. Work on skills capacity within the sector was paused due to the COVID-19 pandemic and will be resumed as soon as possible.
We will work with the Scottish Federation of Housing Associations (SFHA) as the national representative body for Registered Social Landlords (RSLs), and the Glasgow and West of Scotland Forum of Housing Associations, encouraging those bodies to promote the need for positive action measures by their members to address staffing imbalances where there is an underrepresentation of an existing group. Paused Work on skills capacity within the sector was paused due to the COVID-19 pandemic and will be resumed as soon as possible.
By the end of 2018 we will include practice examples covering access for minority ethnic communities and individuals in the revised Social Housing Allocations Practice Guide. Complete The Allocations Guidance was published in February 2019 and was sent to all social landlords. Social Housing Allocations Practice Guide This includes a chapter on equalities and the requirement on social housing landlords to take into account the law on allocations, equality and human rights, as well as regulatory standards and the Scottish Social Housing Charter when deciding on their allocation policies, processes and procedures. The Charter's Equalities Outcome further sets out that social landlords perform all aspects of their housing services so that: every tenant and other customer has their individual needs recognised, is treated fairly and with respect, and receives fair access to housing and housing services. It describes what social landlords, by complying with equalities legislation, should achieve for all tenants and other customers regardless of age, disability, gender reassignment, marriage and civil partnership, race, religion or belief, sex, or sexual orientation. It includes landlords' responsibility for finding ways of understanding the rights and needs of different customers and delivering services that recognise and meet these needs.
Year 3
Action Action Status Update
We will assess the case for an additional specific requirement on the recording and provision of advice provided to minority ethnic communities on the conclusion of the current pilot of the Scottish Standards for information and advice providers. TBC Scottish National Standards for Information and Advice Providers' has finished the pilot phase and will be moving to phase 2 in the near future. This action is currently under discussion and we are looking to determine the correct vehicle for assessing the provision of advice to specific groups.
Multi-year actions
Action Action Status Update
In 2018-19 the SHR will review their Charter indicators, including those related to protected characteristics, in order to help identify further opportunities for improvements in performance against the equalities outcome in the Scottish Housing Charter. This will be subject to full and formal consultation with a view to introducing new or amended equalities indicators. Complete The Scottish Housing Regulator reviewed its regulatory framework including its Charter indicators. Each social landlord must now collect data relating to each and every protected characteristic for their existing tenants, new tenants, people on waiting lists and who apply as homeless, governing body members and staff. We will no longer require equalities data to be submitted to us but we expect it to be readily available if we do ask for it – for example – when we undertake specific equalities thematic work. Landlords who provide Gypsy/Traveller sites must collect data on protected characteristics for these service users. We are working with the social housing sector, EHRC and SHRC to develop guidance that will help landlords to effectively embed equalities and human rights in how they run their organisations and deliver services, and on how data collection can best be delivered. Release of this guidance is imminent as at early December 2020. We require landlords to collect this data because doing so and then assessing it is the first step to gaining a better understanding of, and delivering better services to, their tenants and others. More broadly it helps them deliver their Charter commitments (the first outcome is on equalities) and other obligations on equalities and human rights. This will help to ensure better outcomes for the minority ethnic community and others with one or more protected characteristic. We will start assessing compliance with the requirements on equalities and human rights in the second half of 2021.
We will work with local authorities (through COSLA) and housing associations to identify options for increasing the number of minority ethnic people in housing management roles. Paused PATH (Scotland) are funded by the Scottish Government's Equality Unit for 2017-18, 2018-19 and 2019-20 to undertake a 'Developing Management and Leadership Skills' programme. The Developing Management and Leadership (DMLS) course is a personal development course which uses positive action measures to address imbalances in the representation of people from ME communities in all aspects and levels of public life. This activity has been pauseddue to the COVID-19 pandemic.
Over the course of this Parliamentary term we will make the best use of available housing data and research to identify issues affecting minority ethnic communities and promote race equality. The Scottish Housing Regulator will use the data and intelligence that it gathers on an ongoing basis to inform its regulatory engagement to help ensure that social landlords meet the Scottish Social Housing Charter's standards and outcomes - including those on Equalities and Gypsy/Travellers. Ongoing In October 2018 we published a report on social landlords' progress towards the Scottish Government's minimum site standards for Gypsy/Travellers which showed that over half of social landlords did not meet the standards by the deadline of June 2018. Following this we undertook a consultation on our proposals for how we regulate social housing in Scotland. Our equalities impact assessment of the main proposals in our consultation showed no proposals with negative equalities impacts, two with neutral impacts and 12 with positive impacts. In our new Regulatory Framework that we launched in 2019 we say that:
  • Each social landlord needs to have assurance and evidence that it considers equality and human rights issues properly when making all of its decisions, in the design and review of internal and external policies, and in its day-to-day service delivery.
  • We will require all social landlords to submit an Annual Assurance Statement confirming their compliance or otherwise with the Equalities and Gypsy/Travellers Outcomes in the Charter and confirmation that they are meeting their legal duties in relation to equality and human rights.
  • Each social landlord must collect data relating to each and every protected characteristics for their existing tenants, new tenants, people on waiting lists and who apply as homeless, governing body members and staff.
The work in this area continues and we published a report in October 2020 which outlined the experiences and views of people who use homelessness services and gypsy/travellers about their accommodation. We speak to users of social housing landlord services to ask them about their experiences. This then informs our regulation and raises the profile of particular issues in the social housing sector through our published work. More information on the Scottish Government's site standards can be found at https://www.gov.scot/Publications/2015/05/4938."
We will work with key stakeholders to deliver a communication strategy aimed at tenants, landlords, letting agents and the wider public to make them aware of the changes in the Private Rented Sector ensuring that relevant information is developed for minority ethnic landlords and tenants by engaging with key delivery partners. Complete As part of our strategy, Scottish Government placed links to the training and information resources developed by Shelter (with SG funding) on the SG website. Proposals for communication of the new Private Residential Tenancy were submitted from Young Scot, Scottish Association of Landlords and Living Rent. The model private residential tenancy and easy read notes were translated into Urdu, Punjabi and Polish. Translated version of the model Private Residential Tenancy and Easy Read Notes are now available on the Scottish Government website. A new microsite on private renting aimed at young people has been developed and is now available via the Young Scot website, this was accompanied by a targeted 3 month social media campaign. More recently, we have run a further three social media campaigns in 2020, as well as working with stakeholders to disseminate information as part of our response to the coronavirus pandemic. This has helped to ensure tenants are aware of their rights, the financial support available and how to access it.
Additional actions generated from Year 2 reprioritisation, the Black Lives Matter movement and/or COVID-19
Action Action Status Update
The Scottish Government published Improving the Lives of Scotland's Gypsy/Travellers jointly with COSLA on 9 October 2019 which includes a number of actions to improve accommodation for Gypsy/Travellers. Delivery of the accommodation actions is supported by a Delivery Plan, overseen by an Accommodation Actions Stakeholder Group. At the start of the pandemic an action on our COVID response was added to the Delivery Plan. Ongoing The Scottish Government recognises that the Gypsy/Traveller community faces clear additional challenges during the pandemic. We published a framework in April 2020 to support local authorities and their partners in local decision making to support Gypsy/Travellers during the outbreak. We reviewed the framework and published a revised version on 25 June that takes into account changing circumstances, while ensuring health protection is maintained. Approaches will vary locally but the current framework recommends options which focus on providing additional sanitation facilities and minimising evictions. Over the coming year, we will build on work in partnership with COSLA during the COVID 19 outbreak to support Councils to provide more and better Gypsy/Traveller accommodation, in line with our commitments in the Gypsy/Traveller action plan.


Email: charlie.goodwin@gov.scot

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