UNIVERSITY OF THE ARTS LONDON

EQUALITY IMPACT ASSESSMENT (EIA)

EIA REPORT FORM
Please see back of this form for EIA Guidance Notes.
1. REMIT
Name of Policy/
Strategy or
Function &
Department

Complaints and Appeals procedures

Purpose of Policy,
Strategy or
Function

To ensure the University has clear procedures for student

complaints appeals which form part of its quality assurance
system, reflect current best practice and ensure cases are
treated seriously without negatively affecting student rights or
impartial judgement on academic progress or any other aspect of
student life at the University.

2. PERSONNEL
RESPONSIBLE FOR EIA
Name of Policy, Strategy or
Function Holder
Department / Rectorate

Steve Marshall University Secretary

Name of person leading EIA

Sheila Suso Runge

Names & roles of

personnel/stakeholders
undertaking EIA

University Secretariat and Registry

Ken Ewings (Head of Counselling, Health

Advice and Disability Student Services)

Melanie Parsons (Case Worker, Student

Services)
Kat Stark (Head of Membership services,
SU)
Jill Brewster (College Manager LCF)
Peter Watson (Director of Academic
Affairs)
Stephen Holden (Senior Administrator
LCC)
Bethan Williams (Equality and Diversity
Officer Students)

3. AGREED EIA TIMELINE

STAGE

DATES

STAGE 1 PRE-EIA
EIA Lead liaises with Diversity Adviser / Officer to
confirm:
a) Purpose (as per Guidance notes)
b) Preparation & Procedure
c) Panellist confirmation (including Note Taker).
STAGE 2 EIA PANEL INFORMS PRELIMINARY EIA REPORT
a) EIA Lead undertakes EIA Panel discussion with a
selection of key, knowledgeable and influential
stakeholders
b) Writes up EIA Report / Recommendations
c) Report reviewed by Diversity Adviser and Senior
Manager.

13th 15th April TBC

STAGE 3 OPEN CONSULTATION INFORMS FINAL EIA

REPORT
a) Open Consultation Period for feedback on EIA Report
via relevant committees, all-staff email, diversity staff
groups or student networks / Reps / Assemblies or
Student Union.
b) Feedback incorporated into final EIA report.

4th 11th June

April

STAGE 4 ENDORSEMENT OF EIA

a) EIA Lead presents Report for endorsement at Diversity
Committee
b) Policy Lead commits to any Action Plan emanating
from the EIA of the policy to agreed timeframes.

STAGE 5 PUBLISHING OF EIA

Endorsed final EIA Report is published on Diversity Team
website.
EIA Lead disseminates to local Team for implementation.

16th June 2010

30th June 2010

3. EVIDENCE, INFORMATION AND GUIDANCE

Please list any Quantitative data used in undertaking this EIA and
attach as one of your Appendices. This may include EO Monitoring
data, Research, Questionnaires, Evaluation or Survey Results* etc.
Please add more Items as appropriate.
Appendic
es
Item 1

Title of document

Type

Equalities analysis of complaints and appeals

2007/08 and 2008/09

Service EO monitoring data.

Item 2

Complaints and Appeals Annual Report

Item 3

Hidden marks A study of women students

experiences of harassment, stalking, violence
and assault.

Includes Equalities data in

the context of a service
report.
NUS research amongst HE
undergraduates, in which
UAL female students
participated.

Please list any Qualitative data used in undertaking this EIA and list
and/or attach as one of your Appendices. This may include Equalities
Guidance or Policies, Codes of Practice, Research or Consultation with
staff / students / service users, Case Studies, relevant experiences or
anecdotes noted in Focus Groups / Projects / Complaints / Case work
that can constructively contribute to the EIA*. Please add more Items
as appropriate.
Appendic
es
Item 1

Title of document

Type

Exceptional Scrutiny Investigation Reports

where they relate to a specific equality strand
e.g. Disability / Ethnicity

UAL Document

Item 2

University of Bradford

Best Practice in Complaints

and Appeals from other HE
Institutions.

University of Warwick Dignity at work and

study (linked to complaints and appeals
procedures).
http://www2.warwick.ac.uk/services/humanresou
rces/newpolicies/dignity
City University complaints webpage:
http://www.city.ac.uk/studentcentre/ace/
Open University complaints webpage:
http://www.open.ac.uk/studentservices/complain
ts/common-issues-of-concern.php#q5

Item 3

QAA Code of Practice for Students with

Disabilities (section on complaints and appeals)
states that Universities should:
1. Ensure that information about all
complaints and appeals policies and
procedures is available in accessible
formats and communicated to students.
2. Have in place policies and procedures to
deal with complaints arising directly or
indirectly from a student's disability.
3. Ensure those involved in complaints or
appeals are provided with training and
guidance on the rights and entitlements
of Disabled students.

* Appendices will not be published with the EIA. Furthermore, any data that is not already in
the public domain, is confidential or might compromise the anonymity of staff / student
contributors can be referred to but is not necessary to disclose in explicit detail here.

4. RESULTS OF EIA DISCUSSION

Please determine how the Equality Impact Assessment identified ways in which the Policy /
Strategy or Function could or does have a POSITIVE , NEGATIVE or NEUTRAL impact for any
of the equality strands listed below.
Please explain the reasons or justification for this impact, referring to any quantitative or
qualitative evidence available to substantiate your responses.
Where the impact is unknown or uncertain, please state UNCLEAR with details of any further
evidence / discussion that may be required even if this is not readily available.
Where it is simply irrelevant for there to be any impact, please state N/A.

Equality
Strand

POSITIVE

a) Gender

There does not appear to be any

disproportionate outcomes for
male or female students in
complaints and appeals.

NEGATIVE

NEUTRAL/
UNCLEAR/ N/A (please delete
as appropriate)

Equality
Strand

POSITIVE

NEGATIVE

NEUTRAL/
UNCLEAR/ N/A (please delete
as appropriate)

b) Race /
Ethnicity

The data showed that there is an

over-representation of BME
students making complaints or
appeals (see appendix 1: EO
Monitoring Complaints and
Appeals).

There is a perspective that BA

courses are tailored to those who
have undertaken FAD, which may
mean individuals who have come
through other routes may need
additional support to develop at the
same rate. The perception that FAD
courses are over-represented with
white middle class students needs to
be proven or disproven by statistical
evidence. However, the impact of
prior qualifications and training may
lead to particular groups of students
being underprepared for HE, may
have raised expectations and may
be more likely to appeal the grades
awarded to them.

The reason for over representation of

BME students making complaints and
appeals is not clear. Appeals panels are
slightly more likely to find in favour of
students from BME backgrounds.
Further consultation should be carried
out to discern the causes of these
trends.
Equalities analysis of complaints and
appeals by student status (home / EU /
International) has not been carried out
to date.

Equality
Strand

POSITIVE

NEGATIVE

NEUTRAL/
UNCLEAR/ N/A (please delete
as appropriate)

c) Disability
(Access)

Overall, the panel felt that the

complaints and appeals process
was accessible to disabled
students. In 0809 around 67% of
all appeals made by disabled
students were allowed
compared to 62% made by nondisabled students. The panel felt
this may indicate that Appeals
Panels are able to recognise the
specific issues faced by disabled
students and on the basis of the
evidence provided to them, are
able to make an informed
judgement as to the validity of
the appeal.

Many issues raised were relating to

the causes of complaints and
appeals, rather than the way they
are processed. How do we take
learning points from complaints and
appeals and ensure they become a
catalyst for improvement?

There appears to be a high proportion

of disabled students making
complaints and appeals, but relatively
low numbers sighting disability as a
feature of their case. It is not assumed
that all disabled students would bring
cases that relate directly to their
disability, but further exploration of the
nature of complaints and appeals
brought by disabled students might
lead to us identifying whether disabled
students are fully aware of their rights
under the DDA.

Occasionally, students may have

multiple disabilities e.g. Chronic
Fatigue and mental health needs.
Can we adapt the process to enable
disabled people to avoid undue
stress or further exacerbate their
condition, particularly where they
have more than one complaint /
appeal happening at the same time?

Equality
Strand

POSITIVE

NEGATIVE

NEUTRAL/
UNCLEAR/ N/A (please delete
as appropriate)

One key area of concern is where a

student may be disabled and has the
right to re-take a part of their
course, but they appear not to be
well enough. What role does the
University have in advising that
student that perhaps it would be in
their benefit not to persist?
Panel members felt the complaints
and appeals documents (including
forms) need to be available in
accessible / clear / plain English
formats in order to ensure they are
accessible to all students.

d) Sexual
Orientation

Some students may experience

estrangement from their family as a
result of coming out, but do not raise
this issue until the point of appeal
(rather than EC). The current
procedures / documentation do not
highlight the type of support or
advice a person in this situation may
expect from the University.

The SU advise them that they dont

have to attend, although it is usually
advantageous to do so. Students are
offered assurance of confidentiality
and information on London LGBT
services where necessary. These
provisions appear to be working well,
although the quality of advice may be
reliant on the knowledge of individuals
working within the SU and University.

Equality
Strand
e) Faith &
Belief

POSITIVE

NEGATIVE

NEUTRAL/
UNCLEAR/ N/A (please delete
as appropriate)

No reference is made to the religious

observance needs of students within
guidelines relating to complaints or
appeals.

No specific issues were raised in

relation to religion or belief and no
statistical analysis had been
undertaken to discern impact on this
cohort.

Guidance from the ECU states that

Universities should consider the faith
observance needs of students when
scheduling meetings. Is this taken
into account when arranging
meetings regarding complaints and
appeals?

f)
Transgender

We do not monitor the trans status of

students and therefore we have no
indication of their experiences in
relation to complaints and appeals.
Guidance for Supporting Trans
students is being developed during July
2010 and should make reference to EC,
Appeals and Complaints.

Equality
Strand

POSITIVE

NEGATIVE

We do not monitor the caring

responsibilities of students and
therefore we have no indication of their
experiences in relation to complaints
and appeals.

g) People
with Caring
Responsibiliti
es
(Children, Elderly,
Disabled relatives,
or Friends at same
address)

h) Social
Economic
Class

i)

Age

NEUTRAL/
UNCLEAR/ N/A (please delete
as appropriate)

(see Race commentary on FAD

courses)

No specific issues were raised in

relation to social class and no
statistical analysis had been
undertaken to discern impact on this
cohort.

No statistical analysis has been

undertaken on the age profile of
complainants / appellants and no
issues were identified by the panel.

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Equality
Strand

POSITIVE

NEGATIVE

j) Generally
Across All
Equality
Strands

The complaints procedures make

reference to the right for
students to make a complaint
relating to discrimination or
harassment.

Issues raised around better

resolution of informal complaint.

OVERALL

NEUTRAL/
UNCLEAR/ N/A (please delete
as appropriate)

Third Party reporting is

recognised as a way of offering
flexibility to those whose cases
are particularly sensitive or
relate to discrimination/
harassment should we consider
offering this?

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5. EIA OVERVIEW
Ideally, a Policy / Strategy or Function that has given due regard for
equality and diversity will encompass key over-arching principles as
enshrined in UK Equality Legislation, Regulations, Public Duties and
appropriate Codes of Practice.
For some policies, such equality principles may be generally
irrelevant or not-applicable, in which case the Policy may likely have
a NEUTRAL impact in Section 4.
Please indicate, how far you believe your Policy / Strategy or
Function currently meets the below principles. You can make further
explanatory notes in section i).
Generic Equality Principle
a) Has eliminated or reduced possibility of:

i) direct discrimination
ii) indirect discrimination*
b) Promotes equality of opportunity

YE
S
x

NO

c) Has involved and consulted with diverse staff /

students / service users (particularly Disabled

people)
d) Identifies and/or anticipates differences in need,
access & participation and offers appropriate
provision/resources
e) Promotes positive attitudes and good relations
between people from and within different
equality strands
f) Informed by equal opportunities monitoring and
analysis
g) Considers and sets out reasonable steps to
address disadvantage/exclusion and where not
possible, explains why this is justifiable
h) Aligns itself with the priorities of the Universitys
Equality and Diversity Schemes, Policies and
Strategies
i) NOTES

PARTL N/A
Y

x
x
x
x
x
x

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*Indirect discrimination is a rule or condition, which is applied equally to everyone but can be
met by a considerably smaller proportion of people from a particular group, usually to their
disadvantage and which cannot be justified on other grounds.

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6. RECOMMENDATIONS FOR EIA ACTION PLAN

As a result of identifying the equality impact of this Policy /
Strategy / Function, please detail any changes or actions you
propose to make or formalise (including timelines) to:
a) The scope of the Policy / Strategy or Function.
Clearer information on the way in which complaints can be resolved informally and at
which points mediation may be offered. List contacts for support, e.g. SU, Deans Office,
Diversity team (on equalities issues / discrimination) and external agencies where
relevant? Guidance to students / Website end of July 2010
As a preventative measure, include a list of common issues of concern for students; with
tips on how to resolve the case before it becomes a formal complaint (see OU webpage
included on page 3 of this document). Guidance to students / Website - end of July 2010

b) The wording of the Policy / Strategy or Function.

Revise the procedures and all associated forms /guidance documents to ensure they
conform to basic accessibility and reader clarity. Procedures end of July 2010
Explore options for adapting the procedures for students who have more than one
complaint and / or appeal running at the same time, to enable separate cases to be dealt
with under one procedure.
Outline what safeguards are in place to ensure sensitive issues presented by students will
be dealt with in a supportive way, making specific reference to students who have mental
health needs, have experienced violence or assault, who may have to declare their sexual
orientation or trans status as part of an appeal. Consider Third Party reporting for
complaints. Procedures end of July 2010
Ensure where possible, requests by students to attend meetings at times that do not clash
with their religious observance will be considered and adapted to wherever it is reasonable
to do so. Include reference to this within Guidance to students. Procedures end of July
2010

c) The implementation of the Policy / Strategy or Function.

Clarify what kind of reasonable adjustments might be available to disabled students in
undertaking complaints / appeals e.g. booking an accessible venue for a meeting,
accessible information, BSL interpreter etc. Guidance to students and Guidance to staff (if
developed) - end of May
Will there be guidance to staff on effective facilitation of an informal complaint?

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d) The promotion of the Policy / Strategy or Function.

Provide links from the complaints and appeals pages to other relevant information (and
vice versa) e.g.:
- Student Services specifically counselling and disability services
- Student Union Advice pages
- Diversity team pages on harassment and discrimination. Website resource end of
July 2010

e) The resourcing / enabling factors of the Policy / Strategy or

Function.

Provide resources and training to staff involved in complaints and appeals, specifically in
relation to: Reasonable Adjustments and Disabled Students, Diversity team / Central
Disability Team Autumn 2010
Trans-gender students, Diversity team Autumn 2010
General Equalities training (online) Diversity team Autumn 2010.

f) The monitoring of the Policy / Strategy or Function.

In addition to data on race, disability and gender, include analysis of complaints and
appeals by:
student status (Home / EU / International)
Prior qualification (FAD / Btec etc)
social class,
religion (when available),
dependants / caring responsibilities,
age
in future Equal Opportunities and Complaints & Appeals Monitoring Reports to discern
differential impact of students from diverse backgrounds. Data to be collated by the
Diversity team by November 2010 and annually from then on.
As part of Student Focus Groups being established in 2011 by diversity team, include
questions on participants experience of the complaints and appeals procedures to monitor
the impact in an ongoing way. Spring 2011

g) Other please specify

The high rate of appeals by disabled students may be linked to their awareness of being
able to apply for Extenuating Circumstances, leaving them in a position whereby they do
not declare until at the appeals stage. Therefore, it may be worth exploring student
awareness of EC and how disability is addressed within this area. The EC form outlining
eligible grounds could be further clarified in terms of the rights of those with caring
responsibilities.

a) When will you have completed and implemented these changes /

actions?
See dates set under each of the above sections.

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7. FURTHER ENQUIRY
Other than the actions stated in your Recommendations / Action
Plan, will you require any further information / data / consultation to
complete this Equality Impact Assessment?
YES

NO

UNCLEAR

If Yes, please give further details:

Information
Consultation will be carried out with students in Spring
required:
Term 2010 to discern the impact of revised procedures
How to be
Focus Group or other consultation mechanism with
sourced/considered:
targeted invites to disabled students.
By when:
Spring 2010

8. EIA FINAL CHECKLIST

Before your EIA can be finalised, you will need to confirm the
following:
a) Has a member of the Diversity Team reviewed this EIA?

Yes

b) Has your senior manager reviewed and approved this EIA?

Yes

c) i) Has your consultation involved

people/representatives/advocates from the various equality
strands in your consultation? Please confirm who you have
involved and consulted with on this EIA:

No

Student Union Advice Workers

Complaints and Appeals Network
c) ii) Has any consultation specifically involved Disabled
people?
d) Has this EIA been discussed at any University
Committees/Groups? Please detail below:

Pending
Yes

UAL Complaints and Appeals Network

e) Please state the date that you wish to present your EIA at
Diversity Committee for final endorsement.

16th June

Diversity Committee meetings take place twice a term each

academic year and usually happen between 2-4pm in a
Central Services venue. An EIA endorsement slot will usually
take between 15-30 minutes.

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APPROVED BY DIVERSITY
COMMITTEE ON:

16th June 2010

EIA PUBLISHED ON:

21st June 2010

17

Equality Impact Assessments (EIA): Guidance Notes

1. Context
The need for Equality Impact Assessments arises from the Universitys
legal Public Duties actively to ensure that discrimination is being
eliminated and equality positively promoted. It is a specific duty under
these requirements, in the same way that the University must have a
policy or scheme, monitor staff and student numbers and progression,
and publish the policy and scheme and the results of monitoring.
2. Purpose & Operation
The purpose of an EIA is to conduct a thorough analysis to ensure:
a. That there is or will be no adverse, discriminatory, negative
impact on any group in relation to a University policy, strategy or
function.
b. That the policy, strategy or function is making a positive
contribution to equality and promoting diversity in every way
possible/
Changes to the policy, strategy or function should be agreed and
implemented if the EIA identifies:
a. a NEGATIVE impact exists, or could exist in the future
b. a potential POSITIVE impact could exist or be extended to other
equality strands.
All impacts or recommended changes to a policy should be clearly
identified and justified. In some cases, the impact will be UNCLEAR and
may require the collection of further information or evidence, if this is
available. Any recommendations should inform the final EIA Action Plan
along with agreed timelines for implementation.
3. Scope
An EIA should be undertaken on all new policies, strategies and functions,
as part of the process of their development. For existing policies or
functions they should be undertaken as far as possible as part of the
normal cycle of review. Policyholders will be informed before the start of
the Academic Year if their policy has been selected for EIA by the
Diversity Committee.
4. Consultation
EIAs should involve consultation and involvement from a range of
stakeholders and people / representatives from different equality strands.
This is particularly the case for the involvement of Disabled people, which
is a legal requirement under the Disability Equality Duty. The Diversity
Team can be consulted on conducting EIAs.
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5. Endorsement
University-wide Policy EIAs will be a standing item at Diversity Committee
where progress will be regularly reviewed. EIAs of local College policies
should be led by the relevant Diversity Sub-Committee. The results of all
EIAs will be published on the Diversity Teams website.

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