ADMINISTRATION
OF THE NILGOSC PENSION SCHEME
EQUALITY
IMPACT ASSESSMENT
OCTOBER 2002
Summary
1. NILGOSC undertook to carry out an impact assessment of the
way it administers the pension scheme regulations when it published its
Equality Scheme. This document is the final impact assessment.
2. If you have difficulty reading or understanding this
document please contact NILGOSC for an alternative version at the address shown
below.
3. NILGOSC is the Northern Ireland Local Government Officers’
Superannuation Committee – in other words it is the government body which
administers the Local Government Pension Scheme (LGPS). The LPGS is legislation
which is made by the Department of the Environment (the Department).
4. The Department has carried out an impact assessment on the
LGPS regulations. It has determined that there is an adverse impact on some
people due to the way the regulations work. Comments can be made directly to
the Department on this.
5. NILGOSC administers the regulations, rather than
makes them. This impact assessment concentrates on how it administers them and
determines if this is done in a way to cause an adverse impact on specific
groups of people.
6. In order to assess the existence and magnitude of the
adverse impact statistics and other research were utilised.
7. There is an adverse impact on people of different race and
people with/without a disability arising from using written English as the form
of communication in some instances. Using proxy measures this could impact on
1,200 members or pensioners. This impact can be mitigated by a proposed scheme
which will provide those who register with alternative communication methods as
well as such methods being available on request.
8. There is an adverse impact on people who have changed gender
as the gender recorded on birth certificates cannot be changed in Northern
Ireland. No data is available to show the number of people affected. The impact
is currently mitigated by using any change of name and not referring to the
birth certificated sex in correspondence.
9. Comments on the draft impact assessment have been received
and considered by NILGOSC in the compilation of the final report. A summary of
the comments received is shown in Annex C.
Further copies of the Assessment are
available from the address above or it can be read on the internet at www.nilgosc.org.uk/equality.htm
10. NILGOSC will follow-up action taken with a satisfaction
survey.
Contents
If you have difficulty
reading or understanding this document please contact NILGOSC for an
alternative version.
Post/Person NILGOSC,
Templeton House, 411 Holywood Road, Belfast BT4 2LP
Phone 028 9076 8025
E-mail info@nilgosc.org.uk
1. Introduction
1.1 In April 2000
the Northern Ireland Local Government Officers’ Superannuation Committee
(NILGOSC) published its Equality Scheme. In the Scheme it set out its
commitment to expose the administration of the Local Government Pension Scheme
and Discretionary Payments Regulations to an equality impact assessment in
2002.
1.2 The Scheme
also set out the intention to undertake an assessment of the methods of
providing information to stakeholders.
1.3 This document
assesses the impact of the administration of the various regulations and
methods of communication on the nine groups specified in Section 75 of the
Northern Ireland Act 1998 with which NILGOSC is committed to have due regard to
the need to promote equality of opportunity. These groups are:-
·
persons of
different religious belief, political opinion, racial group, age, marital
status or sexual orientation
·
men and
women generally
·
persons with
a disability and persons without
·
persons with
dependants and persons without.
2. What is NILGOSC?
2.1 NILGOSC is the
pension scheme for the employees of over 200 public sector organisations in
Northern Ireland including the 26 councils, the non-teaching staff of schools,
colleges, education and library boards and the University of Ulster, the
Northern Ireland Housing Executive, Translink, and many housing associations.
2.2 NILGOSC is
managed by a Committee appointed by the Department of the Environment. The
Department also make the pension scheme legislation. The staff of NILGOSC undertake
the administration of the Scheme rules as a service to the employers in the
Scheme. Each employer in the Scheme is also responsible for complying with the
Scheme rules.
3. The Policies Under Review
3.1 NILGOSC is
responsible for the administration of the following legislation:-
·
Local
Government Pension Scheme Regulations (Northern Ireland) 2000 and amendments
·
Local
Government Pension Scheme (Management and Investment of Funds) Regulations
(Northern Ireland) 2000 and amendments
·
Local
Government (Discretionary Payments) Regulations (Northern Ireland) 2001.
3.2 This impact
assessment will examine how NILGOSC administers the regulations. It will
concentrate on those areas where NILGOSC has discretion as regards how it
carries out the administration.
4. The Pension Scheme Regulations
4.1 The making of
the regulations is the responsibility of the Department of the Environment.
Before the regulations are made the Department carries out an equality impact
assessment.
4.2 The Department
undertook an impact assessment of the Local Government (Discretionary Payments)
Regulations (Northern Ireland) 2001 in August 2001.
4.3 The Local
Government Pension Scheme Regulations (Northern Ireland) 2000 are in the
process of being replaced with the 2002 regulations. An impact assessment has
been completed following consultation.
4.4 Although
NILGOSC is not responsible for the regulations it provides advice to the
Department at the drafting stage. It also responds as a consultee when the
Department carries out an impact assessment. NILGOSC also provided comments to
the Department when it was preparing its Equality Scheme and screened the
policies for impact assessment. NILGOSC has made submissions to the Department
on the impact of the regulations on the nine categories specified in the
Northern Ireland Act and will continue to do so as well as act as a channel for
comments of any members and employers in the Scheme.
4.5 The Department
has determined that the updated regulations have a differential/adverse impact
on the following:-
·
between men
and women generally
·
between
persons with dependants and persons without
·
between
persons of different age
·
between
persons of different marital status, and
·
between
persons of different sexual orientation.
4.6 No
differential/adverse impact has been identified:-
·
between
persons of different religious belief, political opinion or racial group;
·
between
persons with a disability and persons without.
4.7 A copy of the
Department’s impact assessment is shown in Annex A. Written comments on its
assessment can be made to
Eithne Gribben,
Local Government Division,
Department of the Environment,
Room 5.42,
Clarence Court,
10-18 Adelaide Street,
Belfast,
BT2 8GB.
Fax: (028) 9054 0025
Email: eithne.gribben@doeni.gov.uk
5. Administration of the Scheme
5.1 NILGOSC has
little discretion as to how it administers the pension scheme
legislation. The following are areas in which NILGOSC must exercise judgement
and will be examined in greater detail:-
·
Admission of
Employing Authorities
·
Pension
payment methods
·
Calculation
of benefits
·
Ill-health
retirements
·
Death grant
payments
·
Complaints
procedure
·
Communication
methods
5.2 Admission
of Employing Authorities
5.2.1 All employees
working for employers in the pension scheme are automatically admitted as a
member of the Scheme unless they choose to opt-out. Each employer is
responsible for informing NILGOSC of new employees joining the Scheme and those
who later decide to leave.
5.2.2 However the
decision to admit a new employer to the Scheme is made by the Committee in
compliance with the regulations. Although the Committee will interpret the
regulations any body which is dissatisfied with the Committee’s decision may
refer the matter in writing to the Department for determination.
5.3 Entitlement,
calculation and payment of benefits
5.3.1 The Local
Government Pension Scheme Regulations (Northern Ireland) 2000 sets out in
regulations j2 and j3 the issues for which the Committee is responsible for
deciding. The issues are the following:
(a) what
previous service a member is entitled to count as a period of membership or
a period which determines his/her eligibility for benefits;
(b) whether,
and if so what, periods of service as a part-time employee are included in such
a period;
(c) what
proportion of whole-time service any such period represents;
(d) whether
a payment in lieu of contributions has been made or equivalent pension benefits
have been assured under Part III of the National Insurance Act (Northern
Ireland) 1966;
(e) what
rate of contribution the employee is liable to pay;
(f) whether
a member is entitled to count any added years or additional period, and if so,
how many, as a period of membership;
(g) whether
a member is a Class A, Class B or Class C member for the purposes of deciding
the Inland Revenue maxima which apply to his/her benefits;
(h) whether
a member is entitled to a benefit, including a return of contributions, and the
amount of the benefit.
5.3.2 Full details as
to how these matters are decided are set out in the NILGOSC Employer’s Guide
available from the NILGOSC offices or from the NILGOSC website at www.nilgosc.org.uk/Employer%20Guide/guideintro.htm.
In practice these decisions are made by reference to the LGPS regulations, the
Scheme actuary or other guidance such as the rules set out by the Inland
Revenue.
5.3.3 Any member
dissatisfied with a decision taken by the Committee may invoke the Complaints
procedure and, if exhausted, refer the matter to the Pensions Ombudsman.
5.4 Pension
payment methods
5.4.1 The preferred
method of paying the monthly pension is by BACS which ensures that each
pensioner receives their monthly pension into their bank account on the last
banking day of each month. Most pensioners receive their pension by this method
however 7.5% receive their pension by crossed cheque.
5.4.2 Payment by BACS
is preferred as it is secure, it ensures that cleared funds are in the
pensioners account on pay-day, it is not affected by postal strikes or delays
and has a reduced administration cost.
5.5 Ill-health
retirements/good health
5.5.1 A member is
entitled to a pension and retirement grant at any age on the grounds of
permanent ill-health provided that one of the Committee’s independent doctors
has certified that the member is incapable of performing the duties of his/her
current post due to permanent incapacity of mind or body.
5.5.2 On receipt of an
application for ill-health benefits, NILGOSC will arrange an appointment for
the member with one of the three Committee doctors who hold surgeries across
Northern Ireland. If the member is unable to attend a surgery a house call is
arranged. Following the assessment the doctor will inform the Committee, having
considered the individuals job description, medical condition and any other
medical reports, whether the individual is permanently unfit to work in their
current post.
5.5.3 A two stage
appeal mechanism is in place for those members who are turned down on medical
grounds and remain dissatisfied with the decision. The stage involves a review
by the Secretary of all medical evidence and a report from the Committee
doctor. The second stage review is undertaken by the Committee which will also
consider a report by two of the Committee’s doctors. Ultimately the matter can
be referred to the Pensions Ombudsman or be determined by the court.
5.6 Death
grant payments
5.6.1 When a member or
a pensioner dies there may be a lump sum payable to the next of kin or personal
representatives of the deceased.
5.6.2 A member or
pensioner may nominate in writing any person(s) or body(ies) he/she wishes to
be the beneficiary of the death grant. The Committee will normally have regard
for such nomination when it pays the death grant but it is not bound to do so.
The Committee has absolute discretion with regard to whom, and in what
proportions, it makes payment of the death grant (this is necessary to exempt
such grants from Inheritance Tax).
5.6.3 In making its
decision as to who should benefit from the death grant the Committee will
consider the deceased’s personal circumstances as well as any nomination made.
Often no written nominations are made.
5.6.4 If a nomination
exists and it appears consistent with the deceased’s personal circumstances,
especially if it directs payment to a spouse and/or child, then the payment
will be made in compliance with the nomination.
5.6.5 If there is no
nomination or the nomination appears out of date the personal circumstances of
the deceased will be considered, in particular who lived at the same address
and who is paying for the funeral expenses.
5.7 Complaints
procedure
5.7.1 NILGOSC operates
a general complaints procedure which is compliant with the pension scheme
regulations and the guidance produced by the Equality Commission.
5.7.2 If a
person or organisation has a complaint they should follow this procedure:-
5.7.3 Contact
the person with whom the complainant was dealing, or if preferable, his or her
Manager to try to resolve the problem. This can be done in writing, by
telephone or by personal visit (no appointment necessary).
5.7.4 If
the matter is not resolved to the complainant’s satisfaction he/she can make a
formal complaint, in writing, to the Secretary .
5.7.5 The
complaint will be answered within five working days. Where this is not possible
an acknowledgement will be issued within five working days to advise when a
reply will be received.
5.7.6 If
the complainant is not satisfied with the reply received he/she can ask the
Committee to reconsider the matter. For
a complaint to be reconsidered, it must be submitted in writing, within six
months of receipt of the previous decision, giving the reasons for
dissatisfaction.
5.7.7 The
Management Committee will reconsider the complaint and inform the complainant
in writing, within two months, of its decision. If the complainant is still not
satisfied there are a number of organisations that may be able to help. They are as follows:-
·
The
Northern Ireland Ombudsman
·
The
Pensions Advisory Service (OPAS)
·
The
Pensions Ombudsman
·
Occupational
Pensions Regulatory Authority (OPRA)
·
The
Pension Scheme Registry
A brief description of each organisation
and their contact details are provided.
5.7.8 The Complaints
Procedure is published in a special leaflet available from NILGOSC, it is also
published in the Annual Accounts, the Equality Scheme and the Members’ Guide.
Reference to the availability of the Procedure is made in other leaflets from
time to time.
5.8 Communication
methods
5.8.1 The most
traditional and popular method of communication utilised is the written form.
Providing information to members about the rules of the Scheme and the specific
details of the benefits receivable is a complex process best performed by way
of written guides. When an employer or member exercises choices or wishes to
change information held about them the bona fides of the person is important so
a written document or letter is required with a signature.
5.8.2 Various guides
are available for all members/pensioners about certain aspects of the Scheme.
Each member/pensioner will also receive a newsletter once a year informing them
of the performance of the Scheme and updating them on any developments over the
last year or foreseen in the near future.
5.8.3 Written
communication with pensioners is sent directly to the pensioners’ homes.
Written communication with members is via the employers. Any such correspondence
is sent to the employer who is asked to distribute it to their staff who are
members of the NILGOSC scheme.
5.8.4 NILGOSC staff
make and receive an average of 250 telephone calls per day to/from members,
pensioners and employers. As stated above some administration actions can only
be performed on receipt of written instructions however many matters can be
handled through telephone calls. Staff use the BT Typetalk service when
communicating with some stakeholders who have hearing difficulties.
5.8.5 Since 2000
NILGOSC staff have communicated with stakeholders by e-mail, both directly and
in the form of information requests generated from the web-site. Detailed
information can be found quickly on the NILGOSC web-site however this is not
used as a substitute for any of the other means of communication.
5.8.6 Visits to the
office are rare, perhaps 1 or 2 per day, but are readily facilitated without an
appointment. Limited car parking is available which includes a disabled parking
space.
5.8.7 NILGOSC, on
request, undertakes seminars for employers and employees in the work place to
explain the Scheme rules and benefit entitlements.
6. Consideration of Available Data and Research
6.1 The following
quantitative data was used in undertaking the impact assessment:-
·
NILGOSC
pension scheme data 2002
·
NILGOSC
survey of employers’ workforces 2001
·
Equality
Commission – Northern Ireland Population Economically Active aged 16-64 by
religion
·
NI Labour
Force Survey 1999
·
Office of
National Statistics mid-1996 population estimates of visually impaired people
in Northern Ireland.
6.2 NILGOSC holds
records on each of its members and pensioners showing age and marital status.
It has consulted with members and pensioners to determine if individuals would
be willing to provide additional information for monitoring purposes. Those
sampled have indicated that, in general, they would be willing to complete a
monitoring form designed to record information about the 9 Section 75 equality
groups with the exception of political status and sexual orientation.
6.3 The statistics
used show the possible extent of the impact on particular groupings. However in
order to identify adverse impacts research undertaken by NILGOSC staff was
utilised. This research included the analysis of the standard administration
procedures, a review of comments and complaints from stakeholders, and
comparisons with other organisations.
6.4 NILGOSC also
considered in detail information provided by consultees.
7. Assessment of Impacts
7.1 Impact
on those of different Religious Beliefs
7.1.1 NILGOSC does not
hold information on the religious beliefs of its members or pensioners and
therefore has little quantitative data to show adverse impact on any one group.
7.1.2 NILGOSC has
never received a complaint based on a failure to provide equal access to
services because of an individual’s religious belief and has no other evidence
to show any adverse impact.
7.1.3 However some
consultees recommended that further research was carried out. Therefore NILGOSC
will undertake a survey of a representative sample of scheme membership to
determine, inter alia, the religious beliefs of the membership which will be
compared to national figures to give an indication of a potential adverse
impact. If the religious composition of the Scheme matches that of all
employees working for employers in the Scheme then NILGOSC will be confident
that there is no adverse impact on those people of different religious belief.
This survey will be undertaken in 2002/03.
7.1.4 Also on the
advice received as part of the consultation exercise NILGOSC will undertake a
feasibility study on the use of a lo-call telephone charging system. Such a
system allows callers to phone NILGOSC from any part of Northern Ireland and be
charged at a local call rate by the Telecom company. In this way there will not
be an adverse monetary impact on callers from outside the Belfast area. As
there are a higher proportion of Roman Catholics living outside of Belfast if
no action is taken it could result in an adverse impact on those of different
religious belief.
7.1.5 NILGOSC will
publish the results of the above mentioned survey and feasibility study once
complete in accordance with its commitment given in Section 11- Publication of
Results.
7.1.6 Admission
of Employing Authorities
7.1.7 Over 200
employers have been admitted to the NILGOSC scheme following the rules laid
down in the Regulations. NILGOSC has undertaken a survey of its employers which
shows that their employee composition is comparable with the Northern Ireland
workforce as a whole as regards religious belief:-
|
Source |
NILGOSC Employers |
NI Workforce |
|
Protestant and Other |
59.52% |
60.1% |
|
Roman Catholic |
40.48% |
39.9% |
7.1.8 Other
Elements of the Administration of the Scheme
7.1.9 The collection
of monitoring data in the future is discussed later in this impact assessment
however in the absence of such data reliance is placed on anecdotal evidence
and the legislation. The Scheme rules are designed to apply to all members.
Failure to treat members equally, whether due to religious belief or other
grouping, would be a breach of the legislation. As stated above no complaints
have arisen of such a nature and there is no element of the administration
procedures which apply unequally to persons of different religious beliefs. There
is no adverse impact for persons of different religious belief.
7.2 Impact
on those of different Political Opinion
7.2.1 NILGOSC does not
hold information on the political opinions of its members or pensioners and
therefore has little quantitative data to show adverse impact on any one group.
7.2.2 NILGOSC has
never received a complaint based on a failure to provide equal access to services
because of an individual’s political opinion and has no other evidence to show
any adverse impact.
7.2.3 Admission
of Employing Authorities
7.2.4 No substantive
data is available from the employers in the Scheme of the political views of
their employees. Certain employers can be viewed as being of a political
nature. The primary examples are the 26 local councils which represent the
broad spectrum of political opinion. All councils are admitted to the Scheme.
7.2.5 Other
Elements of the Administration of the Scheme
7.2.6 The collection
of monitoring data in the future is discussed later in this impact assessment
however in the absence of such data reliance is placed on anecdotal evidence
and the legislation. The Scheme rules are designed to apply to all members.
Failure to treat members equally, whether due to political opinion or other
grouping, would be a breach of the legislation. As stated above no complaints
have arisen of such a nature and there is no element of the administration
procedures which apply unequally to persons of political opinion. There is
no adverse impact for persons of different political opinion.
7.2.7 Trade Union
activism is classed as a political opinion. NILGOSC is managed by a Committee
which, excluding the Chairman, is comprised of an equal number of trade union
representatives and employer representatives.
7.3 Impact on
those of different Race
7.3.1 NILGOSC does not
hold information on the racial group of its members or pensioners and therefore
has little quantitative data to show adverse impact on any one group.
7.3.2 NILGOSC has
never received a complaint based on a failure to provide equal access to
services because of an individual’s race and has no other evidence to show any
adverse impact. As part of the consultation on the Equality Scheme access to
the Scheme was provided for those whom English was not their first language.
NILGOSC did not receive any requests for the Scheme in a non-English format.
7.3.3 As part of
NILGOSC’s own survey of the employers in the Scheme details of racial groups of
employees were requested however only some employers could provide this
information. Of a population of 5465 employees, 99.8% were recorded as being
White and the remaining 0.2% were non-White. Applying that percentage across
all the Scheme members would indicate that between 100 and 200 members are from
a non-White background.
7.3.4 Communication
with the Scheme members is through their employers. No employer has requested
from NILGOSC any scheme information in a language other than English.
7.3.5 Although there
is no evidence of an adverse impact on any group of different race if an
individual is unable to understand English it is possible that he/she would not
be able to benefit from all of the information currently provided by NILGOSC.
This would arise where an employer has not identified the need to provide that
person with non-English version of NILGOSC documents or the individual is
unaware that NILGOSC provides such documents on request. Therefore
potentially there is an adverse impact on persons of different race. The
most important task NILGOSC undertakes, the calculation and payments of
benefits, would be unaffected as this is organised by the employer.
7.4 Impact on
those of different Age
7.4.1 As regards the
administration of the Scheme there are no inherent features which dictate
different treatment depending on age. Membership of the Scheme is slightly
older that the average labour force but this is to be expected due to the
higher importance of a pension closer to retirement. All employees are
automatically a member of the Scheme until such time as they decide to opt-out.
Therefore, as regards the administration of the Scheme, there is no adverse
impact on persons of different age.
7.4.2 The existing age
profile of the Scheme as at 31 March 2001 is as follows:-
7.5 Impact on
those of different Marital Status
7.5.1 As regards the 7
elements of the administration of the Scheme marital status forms no part of
the administration process and NILGOSC has no evidence to show any adverse
impact. There is no adverse impact on persons of different marital status. The
marital status of the Scheme members reflect the wider population of the
workforce in Northern Ireland as shown in the table below:-
|
|
Married |
Not Married |
|
NI Workforce |
57.9% |
42.1% |
|
NILGOSC members and Pensioners |
59.3% |
40.7% |
NI Labour Force Survey
1999
7.6 Impact on
those of different Sexual Orientation
7.6.1 The Sexual
Orientation of scheme members and pensioners is not recorded by NILGOSC. The
collection of monitoring data in the future is discussed later in this impact
assessment however in the absence of such data reliance is placed on anecdotal
evidence and the legislation. The Scheme rules are designed to apply to all
members. Failure to treat members equally, whether due to sexual orientation or
other grouping, would be a breach of the legislation. No complaints have arisen
of such a nature and there is no other evidence showing adverse impact.
Therefore there is no adverse impact on persons of different sexual
orientation.
7.7 Impact on
those of different Gender
7.7.1 No distinction
is made in the treatment of males and females. Gender information is recorded
as that on the birth certificate of an individual. At present Northern Ireland
law does not allow changes to the gender recorded on the birth certificate
unless incorrectly recorded at birth. Therefore a female who was born male but
has undergone a sex change operation will be recorded as male. Legislation has
been introduced in England & Wales to allow such changes but there are no
equivalent plans for Northern Ireland. Therefore there is an adverse impact
on persons of different gender. NILGOSC will inform the Department of
Finance and Personnel which is responsible for the General Register Office of
the Northern Ireland Statistics and Research Agency of this adverse impact.
7.7.2 There is no data
available on the number of members of the NILGOSC scheme who have undergone a
sex change operation and wish to have their gender amended from that on the
birth certificate.
7.8 Impact
on those of with and without a disability
7.8.1 No data is kept
on whether members or pensioners have or do not have a disability. However as
the Scheme has over 20,000 pensioners it is cognisant of particular problems in
communicating with those who are deaf, partially deaf, blind or partially
blind.
7.8.2 NILGOSC relies
on the employers of members to alert it to any special communication needs as
the employer is responsible for its employees joining the Scheme and informing
NILGOSC of important information such as hours worked and salary changes.
7.8.3 Members and
pensioners may have need to contact NILGOSC directly concerning retirement
quotes, pay queries, change of details and/or enquiries about means of boosting
their pension such as additional voluntary contributions. Information can be
provided in writing or by telephone. There are no instances where time is of
the essence for such queries therefore there is no disadvantage to using one means
of communication to the other.
7.8.4 Both pensioners
and members will also receive annual information from NILGOSC in writing such
as a summary of the financial statements, a members’/pensioners’ newsletter, a
payslip/P60 or a pension benefit statement. These are not provided in any other
format. For a blind or partially sighted person who cannot see to be able to
read these documents there is an adverse impact of this means of communication.
Therefore there is an adverse impact on persons with and without a
disability.
7.8.5 Using figures
collected by the Office of National Statistics in 1996 as a proxy measure it is
estimated that approximately 1000 members of the Scheme will be partially
sighted, the majority being pensioners. This is based on the percentage for
Northern Ireland as a whole (1.5%) applied to the total of members and
pensioners in the Scheme.
7.9 Impact on
those of with and without dependants
7.9.1 NILGOSC has no
statistical data on the impact of the administration of the Scheme on those
persons with or without dependants. There may be occasion where the
responsibility of caring for a dependant prevents a member or pensioner from
visiting the NILGOSC offices or a NILGOSC doctor. Members are not required to
visit the NILGOSC offices at any time and all communication can be successfully
undertaken by mail, email or telephone. As regards a visit to the NILGOSC
doctor if a person cannot physically visit one of the doctors’ surgeries a home
visit can be arranged. Therefore there is no adverse impact on persons with
or without dependants.
8. Consideration of Alternatives or methods of mitigation
8.1 Communication
8.1.1 The potential
difficulties regarding communication for those persons who do not speak or
write English well or those persons who are blind or partially sighted can be
resolved by a scheme designed to respond specifically to their needs.
8.1.2 The first steps
in this process were taken when the Equality Scheme was published. Alternative
versions of the Scheme (eg. On audio cassette, in non-English language) were
available on request. Steps have also been taken as regard the size of print
used in leaflets aimed at the pensioners of the Scheme. The last Pensioners’
News issued complied with the RNIB’s See It Right guidelines.
8.1.3 With the help of
the employers, NILGOSC will record on a central database any communication
needs of members and pensioners and will produce communication material to suit
those who have difficulty reading the current publications. In this way any
alternative versions of leaflets can be prepared in advance of publication and
issued at the same time as the standard English text versions rather than on
request.
8.1.4 Information
regarding individuals communication needs will be collected during
October-December 2002 and the scheme will operate from 1st January
2003. In the meantime all members and pensioners will be informed that
alternative versions of communications are available in alternative formats on
request.
8.2 Change of
Gender
8.2.1 If a person
changes gender during their life or wishes to be regarded as a member of the
opposite sex NILGOSC will address them as a member of their new/desired gender
in all communications irrespective of the gender stated on the birth
certificate.
9. Formal Consultation
9.1 This impact
assessment was subject to a formal consultation exercise. Consultees included
those individuals and organisations (see Annex B) listed in Appendix I of the
Committee’s Equality Scheme and amended by experience. A public notice was also
placed in the three main newspapers inviting comment from the general public
and other stakeholders.
9.2 The formal
consultation exercise ended on 20th September 2002 thereby allowing
12 weeks for comments to be received.
9.3 A
summary of the comments received is shown in Annex C.
10. Policy Decision Following Consultation Exercise
10.1 This impact
assessment is a review of policies and procedures which are already in operation.
The impact assessment has highlighted the need to change these procedures in
order to mitigate the impact for some groups. The following action will be
taken:-
·
Collection
of details from each member/pensioner of alternative communication needs and
provision of information in the future in the desired format.
·
Undertaking
of a feasibility study of the use of a lo-call telephone charge system
·
Analysis of
the composition of a representative sample of members and comparison with all
employees employed by scheme employers. This exercise should identify if there
is the potential for an employer not to be making membership of the scheme
available to all of its staff.
11. Publication of Results
11.1 NILGOSC will publish by
the most appropriate method to those listed in Annex B and any other
organisation representing some or all of the stakeholders, the outcome of this
equality impact assessment and of any monitoring undertaken in relation to
Section 12 below. The appropriate
method of publication will be determined following consultation with the
affected groups.
11.2 This
material will also be available in printed form by contacting NILGOSC at
Templeton House, 411 Holywood Road, Belfast, BT4 2LP, telephone number 028 90768025.
Alternative formats will be available on request. NILGOSC may inform the general public about the availability of
this material through press releases.
It will also inform bodies listed at Annex B when this material is
available.
11.3 The results of impact
assessments will be posted on the NILGOSC website which is
http://www.nilgosc.org.uk/equality.htm.
11.4 The report on the impact assessment will
include:-
·
Executive Summary
·
Details of the procedures being assessed
·
Collection of data
·
Key Findings
·
Conclusions.
12. Monitoring for Adverse Impacts and Publication of Results
12.1 Adverse impact
is anticipated for those who cannot read the English written word although
mitigating action should remove this adverse impact. Following the formation of
a database to record the communication methods to be used with
members/pensioners a survey will be undertaken to measure satisfaction with the
new procedure. The results will be published as part of the Annual Equality
Statement.
12.2 NILGOSC does not
monitor which of the nine groups detailed in Section 75 each pensioner/member
belongs to with the exception of age and sex. It has consulted with members’
and pensioners’ focus groups to determine if this information could be
captured. Those consulted were happy to provide such information in general
with the exception of political opinion and sexual orientation. However the
information that the consultees were prepared to give would only be given on an
anonymous basis. Therefore sampling will be used to gather representative data
of the total membership.
Annex A
Department of the Environment
DRAFT
EQUALITY IMPACT ASSESSMENT
THE LOCAL GOVERNMENT PENSION SCHEME REGULATIONS (NORTHERN IRELAND) 2000 (S.R. 2000 No. 177)
DRAFT LOCAL GOVERNMENT
PENSION SCHEME REGULATIONS
(NORTHERN IRELAND) 2002
EXECUTIVE SUMMARY
The Local Government Pension Scheme Regulations (Northern Ireland) 2000 constitute the occupational pension scheme for persons engaged in local government and other employment who are members of the scheme.
The Local
Government Pension Scheme Regulations (Northern Ireland) 2002 and the Local
Government Pension Scheme (Amendment No. 2 and Transitional Provisions)
Regulations (Northern Ireland) 2002 are due to be made in the near future after
a consultation exercise. The new
regulations will update and replace with amendments and improvements, the above
current regulations for those persons who are active members of the pension
scheme on or after the commencement date of the new regulations.
The new regulations will provide for the harmonisation and equalisation of the employee’s pension contribution rate to 6% for all new members (at present manual employees pay 5% and others 6%). Existing members who pay 5% will continue to do so provided they remain in manual employment.
Under the
current legislation a pension is payable to a surviving spouse but is not
payable to a surviving opposite sex or same sex partner on the death of a
member. It is not the Department’s
intention to amend this at present but
the issue will be reviewed as early as possible in liaison with Government
Departments responsible for other public pension schemes.
This will be
done in the light of the European Union Council Directive 2000/78/EC of 27
November 2000, taking into account the financial cost of providing for
unmarried survivor benefits. The
Directive, which establishes a general framework for equal treatment in
employment and occupation provides, amongst other things, for protection against unfair discrimination in
respect of sexual orientation to be implemented in UK law by 2 December
2003.
The new
regulations, as with the current regulations, will contain certain age
provisions which are subject to Inland Revenue rules. Again, these provisions
will be reviewed in liaison with other Departments in the light of the above
Directive, which also provides for protection against age discrimination to be
implemented in UK law by 2 December 2006.
The current regulations provide that where a member of the pension scheme dies
after retirement an eligible child is entitled to a pension. The definition of an
eligible child however draws a distinction between a legitimate and an
illegitimate child in that an illegitimate child has to prove financial dependency
whereas a legitimate child does
not. The new regulations will amend the
definition to provide for equal and consistent treatment between both.
BACKGROUND
1. The Local Government Pension Scheme Regulations (Northern Ireland) 2002 and the Local Government Pension Scheme (Amendment No. 2 and Transitional Provisions) Regulations (Northern Ireland) 2002 are due to be made in the near future after a consultation exercise. They will largely replicate regulations made for England, Wales and Scotland.
2. The new regulations will update and replace, with amendments and improvements, the Local Government Pension Scheme Regulations (Northern Ireland) 2000, as amended, for those persons who are active members of the pension scheme on or after the commencement date of the new regulations. They will also provide for the continuation of certain provisions of the current regulations for persons who at that date are not then active members.
3. The Department of the Environment is committed to assessing the above mentioned current regulations for equality impact under the obligations of Section 75 of the Northern Ireland Act 1998. These require all public authorities, in carrying out their functions relating to Northern Ireland, to have due regard to the need to promote equality of opportunity. The other obligation under Section 75 is for public authorities to have regard to the desirability of promoting good relations between persons of different religious belief, political opinion or racial group. This latter obligation is not relevant to the Equality Impact Assessment (EQIA) as the regulations have no impact in these categories.
AIMS OF THE POLICY/NEW REGULATIONS
4. Generally, the new regulations will continue to provide pensions for local government and other employees to whom the Local Government Pension Scheme Regulations (Northern Ireland) 2000 currently apply and introduce certain changes and improvements to the scheme. (See Appendix 1 for examples).
5. Certain differential/adverse impacts resulting from the current regulations will be rectified if appropriate by the new regulations or identified for further consideration in consultation with other Government Departments and interested parties.
CURRENT REGULATIONS
- CONSIDERATION OF AVAILABLE DATA AND RESEARCH
6. The current regulations have been identified by the Department as having differential/adverse impact in the following categories:
-between men and women generally
(gender),
-between persons with dependants
and persons without,
-between persons of different
age,
-between persons of different
marital status, and
-between persons of different
sexual orientation.
7. No differential/adverse impact has been identified in the following categories:
-between persons of different religious
belief, political opinion, or racial group,
-between persons with a disability and persons without.
8. At present approximately 37,667 employees are members of the scheme and over 19,000 people are in receipt of pensions under the scheme, which is administered by the Northern Ireland Local Government Officers’ Superannuation Committee (NILGOSC). NILGOSC is a Non Departmental Public Body appointed by the Department of the Environment and consists of five members nominated by employers’ organisations, five members nominated by employees’ organisations and a chairperson.
9. Data supplied by NILGOSC (see Appendix 2) has been used to measure the differential impact in relation to gender. Where the new regulations will have a mainly positive/equalising impact in respect of dependants and age considerations, the need for data and research was considered unnecessary. Where the new regulations will not address the adverse impact in relation to marital status and sexual orientation considerations, the need for data is necessary to allow for assessment of impact. Such data would raise issues of sensitivity and confidentiality should an attempt be made to collect it from employers and employees. Proxy information from the Continuous Household Survey (CHS), conducted every year in Northern Ireland by the Central Survey Unit, has therefore been used (see following paragraphs).
ASSESSMENTS OF IMPACTS
10. Gender
(a) In the calculation of additional payments by employees
to improve benefits, different actuarial factors are used for male and female
employees. The factors, provided by
the Government Actuary’s Department, take into account the different life
expectancies of men and women. Given
that the European Court did not extend its equality ruling on the Barber case
(May 1990) to actuarially assessed factors, equalisation of those factors is not considered appropriate as there is
a differential but no adverse impact.
(b) At present under the current legislation, manual employees pay 5% of pay in respect of pension contributions whereas non-manual employees pay 6%. It is the Department’s intention from the date the new legislation becomes operational to equalise the contribution rate by having all new members of the scheme pay 6%. (Existing manual employees will continue to pay 5% provided they remain in manual employment).
There are therefore two equality issues here, (i) between current manual and current non-manual workers and (ii) between current manual and new manual workers. With regard to (ii) there would be no data to analyse.
With regard to (i), data supplied by NILGOSC (see Appendix 2) shows the number of male/female members in the pension scheme as at 1 November 2001, broken down into manual/non-manual and into part-timers manual/non-manual.
When part-timers are converted to “full-time
equivalents”(see Appendix 3), 53% of all contributing members are female and
47% male. However in actual number and
percentage terms there are more male than female manual workers. Therefore the retention of the 5%
contribution rate for manual employees will have a greater impact on males than
on females as it will affect 8272 males, representing 55% of the male
workforce, compared to 4658 females covering 28% of the female workforce. This
is a reflection of the gender breakdown of the existing manual jobs concerned
and no mitigating or alternative action is proposed.
11. Dependants
(a) Annual
pensions increase awards are payable under the Pensions Increase Orders made by
the Department of Finance and Personnel under the Social Security Pensions
(Northern Ireland) Order1975. These
increases are paid only to those retirement pensioners who are over 55 unless
their pension is payable as a result of retirement through ill-health or
infirmity or they have one or more wholly or mainly financially dependent
children under the age of 17 or receiving full-time education or training for
at least 2 years. The impact on dependants is positive and no
change is considered necessary.
(b) Where a person dies after retirement an eligible child is entitled to a pension. An eligible child is defined in the current regulations as:
- a legitimate child of a marriage which took place before the date on which he became entitled to the pension, and was born before the first anniversary of that date, or
- a child adopted by the deceased before he became entitled to the pension, or
- a child who was wholly or mainly dependent on the deceased both before he became entitled to the pension and at the time of his death and is -
(1) the deceased’s step-child or illegitimate child;
(2) an adopted child of a person who married the deceased before he became entitled to the pension; or
(3) a child accepted by the deceased as a member of the family.
This means that to be an eligible child entitled to a pension a child who falls into categories (1), (2) or (3) above must be wholly or mainly dependent (i.e. financially dependent) on the deceased person both when employment ceased and at the date of death. However, a legitimate child born up to 12 months of the deceased person’s employment ceasing, or who had been adopted prior to the last day of employment, is an eligible child for the award of a pension without having to be wholly or mainly financially dependent on the deceased either when employment ceased or on death. With the exception of a child born in the year after employment ceased, the possibility of a deceased person’s legitimate or adopted child not effectively being an eligible child (i.e. financially dependent) on both occasions would, of course, be most unlikely.
(c) Under the new regulations the definition of “eligible child” changes to the following -
- the deceased’s legitimate or adopted child ; or
- a child who was wholly or mainly dependent on the deceased at the time of his death or, where the child is born after the member’s death, who would have been so dependent if he had been born before or on the date of the deceased member’s death,
but does not include a child who was born on or after the first anniversary of the date of the deceased’s death.
The test
of financial dependency required in the case of a child who is not the
legitimate or adopted child of a member is extended therefore to include a
child born after the death of a member, who would have been dependent on that
member had the member not died, before the birth. This provides for equal and
consistent treatment between legitimate and illegitimate dependent children.
12. Age
In the calculation of additional payments to be made by employees to improve benefits, different “age last birthday” factors provided by the Government Actuary’s Department are used, subject to Inland Revenue rules. This does not present any basic age inequalities as there is a differential but not an adverse impact. Other age provisions are contained in the regulations, again subject to Inland Revenue rules, and it is the Department’s intention to review these in consultation with other Government Departments in the light of European Union Council Directive 2000/78/EC of 27 November 2000. This Directive provides, amongst other things, for protection against age discrimination to be implemented in UK law by 2006.
13. Marital
Status
(a) A pension is not
payable to a surviving common law spouse/opposite sex partner on the death of a
partner who is a member of the scheme. It is not the Department’s intention to
amend this at present but to review the issue in the light of the above
mentioned Directive which also provides for protection against sexual
discrimination to be implemented in UK law by 2003. This review will be done in liaison with
Government Departments who are addressing the same issue in relation to other
public pension schemes with a view to adopting an alternative or mitigating
policy, taking into account the financial cost of providing for unmarried
survivor benefits.
(b) Information to allow for impact assessment in terms of marital status is unavailable and issues of sensitivity and confidentiality would arise if an attempt were made to collect such information from employers and employees. Proxy information however on those age groups likely to be adversely affected by the regulations obtained from the CHS 2000/2001 indicates that, of all those either cohabiting or married in the age group 50 to 64, less than 1% were cohabiting and would be adversely affected. The percentage for all age groups was 6%.
14. Sexual Orientation
A pension is not payable to a surviving same sex partner on the death of a partner who is a member of the scheme. As above, this issue is to be reviewed in liaison with other Government Departments in the light of the Directive. Information to allow for impact assessment in terms of sexual orientation is unavailable and issues of sensitivity and confidentiality would arise if an attempt were made to collect such information from employers and employees. Proxy information however from the CHS 2000/2001 indicates that of all those either in a same sex couple relationship or married in all age groups, the percentage living in a same sex couple relationship which would be adversely affected was less that 1%.
ALTERNATIVES/MITIGATION
15. The current and proposed legislation
refers separately to spouses and provides for them, but does not provide for
opposite sex or same sex partners.
This could be regarded as indirect discrimination but it is not illegal
under current Northern Ireland legislation. The provision of benefits in respect of
unmarried partners, whether of the same or opposite sex, is being reviewed and
considered in liaison and consultation with Government Departments who are
currently addressing the same issue in other public pension schemes.
16. Before any change could be introduced a further consultation exercise would be undertaken. The provision of unmarried survivor benefits in the equivalent scheme for England and Wales is currently under review by the Department for Transport, Local Government and the Regions (DTLR) in liaison with H M Treasury. The outcome of this review may, to some extent, determine the timetable for implementation of any change. The Department would want as far as possible to implement any change simultaneously with that to the equivalent scheme for local government employees in England, Wales for which DTLR is responsible and also to the equivalent scheme in Scotland.
FORMAL CONSULTATION ON EQIA
17. This EQIA is subject to a formal consultation exercise together with the new draft regulations. Consultees will include relevant bodies (Appendix 4) selected from those listed in Table C1 of the Department’s Equality Scheme as well as those normally consulted by the Department for draft legislation including NILGOSC and all employers contributing to the pension scheme. NILGOSC has already been consulted informally on the EQIA. The Coalition on Sexual Orientation (COSO) was informed by telephone, prior to the formal consultation exercise, of the proposed new legislation and EQIA and was advised that the Department would be willing to discuss same at any time but in any case would welcome comments at formal consultation stage.
POLICY DECISION FOLLOWING CONSULTATION EXERCISE
18. The new regulations will not be made until policy decisions are taken after full consideration of all comments received during the consultation exercise.
PUBLICATION OF RESULTS OF EQIA
19. After the EQIA has been finalised following consultation it will be published on the Department’s website, ndoeclarweb1/, by press release and by publication in Section 75 media. Copies of the EQIA will be available from Eithne Gribben, Department of the Environment, Local Government Division, Room 5.41, Clarence Court, Adelaide Street, Belfast, BT 2 8GB. A copy of the finalised EQIA will be sent to each consultee.
MONITORING FOR ADVERSE IMPACT IN THE FUTURE AND PUBLICATION OF RESULTS
20. Adverse impact is anticipated in relation to pensions in respect of surviving opposite sex and same sex partners on the death of a member. The level of impact however would be impossible to monitor/assess in the absence of data which would be difficult to obtain from employers and employees due to its sensitive and confidential nature. Data from the CHS will continue to be monitored and used as proxy and the results of such monitoring will be published as part of the Department’s Annual Review.
Appendix 1
EXAMPLES OF IMPROVEMENTS AND CHANGES TO BE INTRODUCED TO THE PENSION
SCHEME BY THE NEW REGULATIONS
A standardised contribution rate of 6 per cent. will be introduced for all new members. At present manual employees pay 5% and others 6%. Manual employees currently paying 5 per cent will continue to do so.
Employers will
have a new discretion to reduce or waive a member's contribution once 40 years
of local government employment have been served.
The provision for protecting the value of a member's pension following a change in the circumstances of employment will be extended.
Members and deferred pensioners will have an option to convert part or all of their retirement grant to provide extra pension.
A longer period after retirement i.e. up to age 75 (65 at present), will be allowed before the value of additional voluntary contributions must be used to pay for a pension. This is to take advantage of a change in Inland Revenue practice.
Employers will be allowed to set up a shared-cost additional voluntary contributions (AVC) scheme with members. The facility of a jointly funded AVC scheme will give members the option to transfer the accumulated value of the contributions into additional pension scheme membership.
Employers and NILGOSC will have to formulate, publish and keep under review, policy statements concerning the exercise of their discretionary functions. Employers and NILGOSC will be required to consult each other on the formulation of policy.
Employers will
have the discretion to convert compensation awards made under the Local
Government (Discretionary Payments) Regulations (Northern Ireland) 2001 into
pension scheme membership.
Appendix 2
NUMBER OF MEMBERS CONTRIBUTING TO THE NILGOSC SCHEME
Males Females Total
Non Manual 6899 14560 21459
(57%)
Manual 8590 7618 16208
(43%)
TOTALS 15489 22178 37667
PART-TIMERS IN THE SCHEME ARE INCLUDED IN THE ABOVE FIGURES AND ARE AS FOLLOWS
Males Females Total
Non Manual 270 4639 4909
(43%)
Manual 635 5919 6554
(57%)
TOTALS 905 10558 11463
Appendix 3
NUMBER OF MEMBERS CONTRIBUTING TO THE NILGOSC SCHEME
(with part timers re-calculated as “full-time equivalents”
Males Females Total
non-manual 6764 12240.5 19004.5
manual 8272.5 4658.5 12931
TOTALS 15036.5 16889 31935.5
non-manual 35.59% 64.41% 100.00%
manual 63.97% 36.03% 100.00%
47.08% 52.92% 100.00%
non-manual 44.98% 72.43% 59.51%
manual 55.02% 27.57% 40.49%
100.00% 100.00% 100.00%
Note. The data in this table is not based on actual estimates of employees but is calculated to include part-time workers as full-time equivalents. One full-time equivalent is taken to be comprised of 2 part-time workers.
Appendix 4
RELEVANT BODIES SELECTED FOR CONSULTATION
FROM TABLE C1 OF THE DEPARTMENT’S EQUALITY SCHEME
|
The Equality Unit, Office of the First Minister |
Northern Ireland Human |
|
and Deputy First Minister |
Rights Commission (NIHRC) |
|
|
|
|
Equality Forum NI |
Queer Space |
|
|
|
|
Age Concern Northern Ireland |
Carafriend |
|
|
|
|
Help the Aged, Northern Ireland |
Northern Ireland Women’s |
|
|
European Platform (NIWEP) |
|
Children’s Law Centre |
|
|
|
Women’s Resource and |
|
Child Care Northern Ireland |
Development Agency (WRDA) |
|
|
|
|
Foyle Friend |
Gingerbread |
|
|
Northern Ireland |
|
Child Poverty Action Group (NI) |
|
|
|
Committee on the |
|
NSPCC |
Administration of Justice |
|
|
(CAJ) |
|
Coalition on Sexual Orientation (CoSo) |
|
|
|
Community Relations |
|
Gay and Lesbian Youth |
Council (CRC) |
|
|
|
|
Barnardos |
Northern Ireland |
|
|
Council for |
|
Save the Children |
Voluntary Action |
|
|
(NICVA) |
|
The Rainbow Project |
|
|
|
Women’s Forum |
|
NIGRA |
Northern Ireland |
|
(NI Gay Rights Association) |
|
|
|
Carers’ National |
|
Lesbian Line |
Association |
|
|
|
|
Dr Peter Doran |
NI Committee |
|
NI Assembly |
Irish Congress of |
|
|
Trade Unions (NIC-ICTU) |
NI
Court Service,
- Policy & Legal Branch,
- Civil & Family Branch
Annex B
List of Bodies Consulted
NILGOSC has compiled
the following list of consultees for all matters with a special emphasis on
those who are affected by the pension scheme policies.
This list was
subject to consultation in 2000 and amended as a result.
We will consult directly
with Members and Pensioners by way of a Members Panel and a Pensioners Panel.
These panels will consist of a representative sample of Members and Pensioners.
We expect this form of consultation to be the most effective in ensuring that
all members, including those categorised by Schedule 9 of the Act, have
equality of opportunity for pension scheme matters.
The list below is
not exhaustive and may be amended in the light of experience.
List of
Organisations/Groups to Consult
NILGOSC Staff
Antrim Borough Council
Abode Housing Association Limited
Acorn Integrated Primary School
Agricultural Research Institute of Northern
Ireland
Aquinas Diocesan Grammar School
Ards Borough Council
Ards Citizens' Advice Bureau
Ark Housing Association Northern Ireland Ltd
Armagh City & District Council
Armagh College of Further Education
Armagh Observatory
Armagh Planetarium
Arts Council of Northern Ireland
Ballymena Academy
Ballymena Borough Council
Ballymoney Borough Council
Ballynafeigh Housing Association Limited
Banbridge District Council
Bangor Grammar School
Belfast Charitable Society
Belfast City Council
Belfast Community Housing Association Limited
Belfast Education & Library Board
Belfast High School
Belfast Institute of Further and Higher Education
Belfast Print Workshop
Belfast Royal Academy
Belfast Visitor & Convention Bureau
BIH Housing Association Limited
Bloomfield Collegiate School
Braidside Integrated Primary & Nursery School
Bridge Integrated Primary School
Campbell College
Carrickfergus Borough Council
Castlereagh Borough Council
Castlereagh College of Further and Higher
Education
Causeway Institute of Further and Higher
Education
Cedar Integrated Primary School
Choice Housing Association Limited
Christian Brothers Grammar School
Citybus Limited
Clothing and Industrial Training Services
Coleraine Academical Institution
Coleraine Borough Council
Coleraine Harbour Commissioners
Connswater Housing Association Ltd
Construction Industry Training Board
Convent Grammar School
Cookstown District Council
Council for Catholic Maintained Schools
Council for the Curriculum,Examinations
Countryside Recreation: Northern Ireland
Covenanter Residential Association Limited
Craigavon Borough Council
Dalriada School
Derry City Council
Derry Investment Initiative
Derry Visitor and Convention Bureau
Dominican College
Dominican College
Donacloney Housing Association Ltd
Down District Citizens' Advice Bureau
Down District Council
Drumragh Integrated College
Dungannon & South Tyrone Borough Council
East Antrim Institute of Further and Higher
Education
East Down Institute of Further and Higher
Education
East Tyrone College of Further Education
Engineering Training Council (NI) Limited
Enniskillen Integrated Primary School
Enterprise Ulster
Erne Integrated College
Fermanagh College of Further Education
Fermanagh District Council
Filor Housing Association Limited
Fire Authority for Northern Ireland
Flax Housing Association Limited
Fold Housing Association
Fold Housing Trust
Foyle and Londonderry College
Friends School
Glenmona Resource Centre
Gosford Housing Association
Grove Housing Association Limited
Habinteg Housing Association (Ulster) Limited
Hazelwood College
Hazelwood Integrated Primary School
Hearth Housing Association Limited
Hunterhouse College
Integrated College Dungannon
Jordanstown Schools
Lagan College
Laganside Corporation
Larne Borough Council
Larne Grammar School
Law Society for Northern Ireland
Limavady Borough Council
Limavady College of Further and Higher Education
Linen Hall Library
Lisburn Borough Council
Lisburn Institute of Further and Higher Education
Lisnevin Juvenile Justice Board
Livestock & Meat Commission for Northern
Ireland
Local Government Staff Commission
Loreto College
Loreto Grammar School
Loughview Integrated Primary School
Lumen Christi College
Magherafelt District Council
Malone College
Methodist College
Mill Strand Integrated Primary School
Millennium Forum
Millennium Integrated Primary School
Mount Lourdes Grammar School
Mourne Heritage Trust
Moyle District Council
New-Bridge Integrated College
Newington Housing Association (1975) Limited
Newry & Mourne District Council
Newry/Kilkeel College of Further Education
Newtownabbey Borough Council
North & West Housing Limited
North Coast Integrated College
North Down and Ards Institute of Further and
Higher Education
North Down Borough Council
North East Institute of Further and Higher
Education
North Eastern Education and Library Board
North West Institute of Further and Higher
Education
Northern Ireland Association of Citizens' Advice
Bureaux
Northern Ireland Community Relations Council
Northern Ireland Co-Ownership Housing Association
Limited
Northern Ireland Council for Integrated Education
Northern Ireland Federation of Housing
Associations
Northern Ireland Fishery Harbour Authority
Northern Ireland Hospice
Northern Ireland Hotel and Catering College
Northern Ireland Housing Executive
Northern Ireland Local Government Association
Northern Ireland Local Government Officers'
Superannuation
Northern Ireland Railway Company Limited
Northern Ireland Tourist Board
Northern Ireland Transport Holding Company
Oakgrove Integrated College
Oakgrove Integrated Primary School
Oaklee Housing Association
Oakwood Integrated Primary School
Omagh College of Further Education
Omagh District Council
Ormeau Baths Gallery
Our Lady & St Patrick's College
Our Lady's Grammar School
Presbyterian Housing Association (NI) Limited
Probation Board for Northern Ireland
Rainey Endowed School
Rathgael Juvenile Justice Services
Rathmore Grammar School
Royal Belfast Academical Institution
Royal College of Nursing
Royal School, Armagh
Royal School, Dungannon
Rural Development Council for Northern Ireland
Rural Housing Association
Sacred Heart Grammar School
Saints and Scholars Integrated Primary School
Shimna Integrated College
Slemish Integrated College
South Eastern Education and Library Board
South Ulster Housing Association Limited
Southern Education and Library Board
Spires Integrated Primary School
Sports Council for Northern Ireland
St Columb's College
St Dominic's High School
St Joseph's Adolescent Centre
St Joseph's Grammar School
St Louis Grammar School
St MacNissi's College
St Malachy's College
St Mary's Christian Brothers
St Mary's Grammar School
St Mary's University College
St Matthew's Housing Association Limited
St Michael's College
St Patrick's Boys Academy
St Patrick's Girls Academy
St Patricks Grammar School
Staff Commission for Education and Library Boards
Strabane District Council
Strangford College
Stranmillis University College
Strathearn School
Students Housing Association Co-Op Limited
Sullivan Upper School
Thornhill College
Ulidia Housing Association Limited
Ulidia Integrated College
Ulsterbus Limited
United Dairy Farmers
University of Ulster
Upper Bann Institute of Further and Higher
Education
Victoria College
Wallace High School
Western Education and Library Board
Windmill Integrated Primary School
Woodvale & Shankill Housing Association
Limited
Youth Council for Northern Ireland
Youthnet
Equality Commission
Community Relations Council
Northern Ireland Committee ICTU
NIPSA
Northern Ireland Human Rights Commission
Department of the Environment
NI Council for Ethnic Minorities
Child Care Northern Ireland
Help the Aged
Coalition on Sexual Orientation
Disability Action
NI Anti-Poverty Network
Gingerbread
Committee on the Administration of Justice
West Belfast Economic Forum
NI Association for the Care and Resettlement of
Offenders
RNID NI
Annex C
Comments Received on Draft Assessment
Equality
Commission for Northern Ireland
- Correction
of typographical errors
- NILGOSC
should try to obtain information on the religion/political belief of its
members in order to determine if there is the potential for an adverse
impact or not. If there is potential for adverse impact more research will
be needed to determine the reason(s) for non-participation.
NILGOSC
response: At present all non-casual employees of the employers in the
Pension Scheme are automatically a member of the Scheme unless they choose to
opt-out. It is therefore unlikely that any of the 9 section 75 equality groups
are excluded. However a representative sample of members will be asked to
provide information on their religion and a comparison made with the general
population. Information will not be sought on political opinion because
preliminary discussions with our focus groups indicates that members would be
reluctant to provide such information.
Community
Relations Council
- Offer of
assistance to discuss any issues arising from the Impact Assessment
Northern
Ireland Committee – Irish Congress of Trade Unions
- NILGOSC
should develop statistical and monitoring mechanisms to monitor across the
9 Section 75 equality groups on an annual basis and undertake a further impact
assessment once adequate data is available.
NILGOSC
response: At present all non-casual employees of the employers in the
Pension Scheme are automatically a member of the Scheme unless they choose to
opt-out. It is therefore unlikely that any of the 9 section 75 equality groups
are excluded. However a representative sample of members will be asked to
provide information on their religion and other factors and a comparison made
with the general population. Information will not be sought on political opinion
or sexual orientation because preliminary discussions with our focus groups
indicates that members would be reluctant to provide such information.
Northern
Ireland Fishery Harbour Authority
- Acceptance
of the findings
Loreto
Grammar School
- Acceptance
of the findings and recommendation of co-operation with employers to
reduce adverse impact in communications.
Arts
Council of Northern Ireland
- Useful
to make known which alternative methods of communication are available
- NILGOSC
should consider using a lo-call type telephone facility so that those
living outside a 30km call range do not have to pay a different rate for
contacting NILGOSC.
NILGOSC
response: NILGOSC will undertake an exercise in 2002 to determine which type
of alternative methods of communication suit each member and pensioner. NILGOSC
will also investigate the technical and financial implications of using a
lo-call facility.
South
Eastern Education and Library Board
- Acceptance
of the findings and some useful comments
Ulsterbus
Limited
- Acceptance
of the findings
Enterprise
Ulster
- Acceptance
of the findings
Methodist
College
- Acceptance
of the findings
North
West Institute of Further and Higher Education
- Acceptance
of the findings
East
Antrim Institute of Further and Higher Education
Acceptance
of the findings
Ard’s
Citizens’ Advice Bureau
Acceptance
of the findings with the comment that legislation relating to changes to birth
certificates should be in line with Great Britain.