Equality Scheme for the Northern Ireland Audit Office

Drawn up in accordance with Section 75 and Schedule 9 of the Northern Ireland Act 1998

Updated November 2021.

Foreword

Section 75 of the Northern Ireland Act 1998 (the Act) requires public authorities, in carrying out their functions relating to Northern Ireland, to have due regard to the need to promote equality of opportunity and regard to the desirability of promoting good relations across a range of categories outlined in the Act.

In our equality scheme we set out how the Northern Ireland Audit Office proposes to fulfil the Section 75 statutory duties.

We will commit the necessary resources in terms of people, time and money to make sure that the Section 75 statutory duties are complied with and that the equality scheme is implemented effectively, and on time.

We commit to having effective internal arrangements in place for ensuring our effective compliance with the Section 75 statutory duties and for monitoring and reviewing our progress.

We will develop and deliver a programme of communication and training with the aim of ensuring that all our staff and Non-Executive Members are made fully aware of our equality scheme and understand the commitments and obligations within it.

As Comptroller and Auditor General for Northern Ireland, and head of the Northern Ireland Audit Office, I am fully committed to effectively fulfilling our Section 75 statutory duties across all our functions (including service provision, employment and procurement) through the effective implementation of our equality scheme.

We realise the important role that the community and voluntary sector and the general public have to play to ensure the Section 75 statutory duties are effectively implemented.  Our equality scheme demonstrates how we will ensure there are opportunities, for people affected by our work, to positively influence how we carry out our functions in line with our Section 75 statutory duties.  It also offers the means whereby persons directly affected by what they consider to be a failure, on our part, to comply with our equality scheme, can make complaints.

On behalf of the Northern Ireland Audit Office, I am pleased to support and endorse this equality scheme, which has been drawn up in accordance with Section 75 and Schedule 9 of the Northern Ireland Act 1998 and Equality Commission guidelines.

KJ Donnelly

Comptroller and Auditor General

9 December 2021

Chapter 1

Introduction

Section 75 of the Northern Ireland Act 1998

Section 75 of the Northern Ireland Act 1998 (‘the Act’) requires the Northern Ireland Audit Office (‘the NIAO’ or ‘the Office’) to comply with two statutory duties:

1. Section 75(1) - in carrying out our functions relating to Northern Ireland, we are required to have due regard to the need to promote equality of opportunity between:
   1. persons of different religious belief, political opinion, racial group, age, marital status or sexual orientation;
   2. men and women generally;
   3. persons with a disability and persons without; and
   4. persons with dependants and persons without.
2. Section 75(2) - in addition, without prejudice to the obligations above in carrying out our functions in relation to Northern Ireland, we are required to have regard to the desirability of promoting good relations between persons of different religious belief, political opinion or racial group.
3. ‘Functions’ include the ‘powers and duties’ of a public authority (as set out in Section 98(1) of the Northern Ireland Act 1998), which includes our employment and procurement functions.

How we propose to fulfil the Section 75 duties in relation to the relevant functions of the Northern Ireland Audit Office

4. Schedule 9 4(1) of the Act requires the NIAO as a designated public authority to set out in an equality scheme how it proposes to fulfil the duties imposed by Section 75 in relation to its relevant functions.  This equality scheme is intended to fulfil that statutory requirement.  It is both a statement of our arrangements for fulfilling the Section 75 statutory duties and our plan for their implementation.
5. The NIAO is committed to the discharge of the obligations under Section 75 in all parts of our organisation, and we will commit the necessary resources in terms of people, time and money to ensure that the Section 75 statutory duties are complied with, and that our equality scheme can be implemented effectively.

Who we are and what we do

6. The Comptroller and Auditor General for Northern Ireland (C&AG), who is head of the NIAO and an Officer of the Northern Ireland Assembly, is responsible for:
   • authorising the issue of money from the Northern Ireland Consolidated Fund to enable Northern Ireland Departments to meet their necessary expenditure and ensuring that there are adequate arrangements for the collection of revenue; and
   • the external audit of central government bodies in Northern Ireland, including Northern Ireland departments and their executive agencies and a wide range of other public sector bodies, including  Non-Departmental Public Bodies, health and social care bodies and public sector companies limited by guarantee.  The results of this work are reported to the Assembly.
7. The status, functions and main duties of the C&AG, who is wholly independent of government, are set down in legislation, including the Audit (Northern Ireland) Order 1987, the Northern Ireland Act 1998, the Government Resources and Accounts Act (Northern Ireland) 2001 and the Audit and Accountability (NI) Order 2003. In accordance with the 1987 Order, the C&AG is responsible for appointing and determining the terms and conditions of the staff of his Office, the NIAO, which supports him in fulfilling his functions.  NIAO currently has 125 employees (119 FTE).
8. A senior member of NIAO staff is designated by the Department for Communities, with the consent of the C&AG, as the Local Government Auditor.  This member of staff has responsibility for the external audit of all local government bodies. The principal legislative authority for the responsibilities of the local government auditor is contained in the Local Government (Northern Ireland) Order 2005, the Local Government Act (Northern Ireland) 2014 and the Local Government (Accounts and Audit) Regulations (Northern Ireland) 2015.
9. As a corporation sole, the C&AG is responsible for establishing the internal governance structure of the NIAO to support him in the delivery of his statutory functions.  The structure currently comprises a NIAO Senior Management Team, Audit and Risk Assurance Committee (composed solely of non-executive members), Remuneration Committee and an Advisory Board.  The Senior Management Team is the principal mechanism for decision making in NIAO and consists of the C&AG, Chief Operating Officer and 6 Directors. Operationally, NIAO is divided into directorates:
   • Five directorates deliver the audit programme comprising Financial Audit and Public Reporting; and 
   • One directorate is responsible for Corporate Services
10. The key objectives of financial audit are to:
    • provide reasonable assurance that the financial statements audited by the Office give a true and fair view, have been prepared in accordance with the relevant accounting and other requirements and are in accordance with the authorities that govern them;
    • identify, assess and examine risks to regularity, propriety and financial control in audited bodies and report on significant weaknesses; and
    • provide audited bodies with constructive advice that will help them improve their corporate governance, financial management, control and reporting.
11. Financial audit is conducted in accordance with International Standards on Auditing (UK and Ireland).  Those standards require compliance with the Financial Reporting Council’s Ethical Standards for Auditors.
12. The main element of the NIAO’s public reporting activity is the C&AG’s value for money investigations.   The NIAO seeks to promote better value for money by examining and reporting on whether public bodies spend public money economically, efficiently and effectively.  The NIAO also suggests ways in which public bodies can achieve their aims and objectives more cost-effectively, using accepted audit methodologies.  A structured approach is adopted in selecting topics for examination, based on factors including an assessment of risk, the potential for improving value for money and public interest.
13. Draft reports are cleared with the audited body and, where appropriate, relevant third parties.
14. The results of the C&AG’s work are reported to the Northern Ireland Assembly and published as Assembly documents.  The Assembly’s Public Accounts Committee takes evidence from senior officials on these reports and, following consideration of evidence, reports its findings and recommendations to the Assembly.  The Northern Ireland Executive is required to respond to the Committee’s recommendations, specifying the action which the audited body intends to take in response.  The NIAO then monitors the actions taken.
15. As noted above, the C&AG’s responsibility is to report to the Assembly and as such he does not provide services directly to the public.  However, the NIAO does welcome approaches from those who have concerns about the use of taxpayers’/ratepayers’ money and wish to pass these on to the NIAO.  This is often a valuable source of intelligence and insight to inform us of the systemic issues that we should be focusing on.
16. In relation to concerns raised by public employees, the C&AG has been prescribed as a person to who protected disclosures can be made under the Public Interest Disclosure (NI) Order 1998.  He has a role in relation to the proper conduct of public business, value for money, fraud and corruption in relation to the provision of centrally-funded public services.  The Local Government Auditor has been similarly prescribed in relation to local government bodies.
17. The Office also participates in the National Fraud Initiative together with other UK public sector audit agencies. This participation is carried out in accordance with provisions inserted in the Audit and Accountability (Northern Ireland) Order 2003 by the Serious Crime Act 2007 which enable the C&AG to conduct data matching exercises for the purpose of assisting in the prevention and detection of fraud.
18. The Office’s Corporate Services directorate supports the delivery of the above range of functions, having responsibility for resources (finance and human resources), equipment, supplies and other services. Responsibility for NIAO procurement procedures rests with this directorate, as does responsibility for the Office’s equality function, including overseeing the implementation of the Equality Scheme.
19. Further information on the NIAO can be found on the Contact Us section of this website.

Chapter 2

Our arrangements for assessing our compliance with the Section 75 Duties

20. Some of the arrangements for assessing compliance with the Section 75 statutory duties are outlined in other relevant parts of this equality scheme, for example in the chapters regarding arrangements for consulting; assessing, monitoring and publishing the impact of policies; and complaints procedure etc.  In addition we have the following arrangements in place for assessing our compliance:

Responsibilities and reporting

21. We are committed to the fulfilment of our Section 75 obligations in all parts of our work.
22. Overall responsibility for the effective implementation of our equality scheme lies with the Comptroller and Auditor General.  The Director of Corporate Services has responsibility for the development, implementation, maintenance and review of the equality scheme in accordance with Section 75 and Schedule 9 of the Northern Ireland Act 1998, including any good practice or guidance that has been or may be issued by the Equality Commission. The Director is assisted in this role by a team of NIAO staff, including the Human Resources Manager.
23. If you have any questions or comments regarding our equality scheme, please contact us using the following details in the first instance, and we will respond to you as soon as possible:

Brian O’Neill

Director of Corporate Services

Northern Ireland Audit Office, 106 University Street, Belfast, BT71EU

028 9025 4323

equality@niauditoffice.gov.uk

24. Objectives and targets relating to the statutory duties are integrated into NIAO’s business plans.  Progress will be monitored and reported regularly to NIAO’s Advisory Board and Senior Management team.
25. The personal objectives of those directly engaged in this work reflect their contributions to the discharge of the Section 75 statutory duties and the implementation of the equality scheme, and are subject to appraisal in the annual performance review.  In addition, all job roles reflect a commitment to the principles of equality, fairness and diversity.
26. The NIAO prepares an annual report recording the progress made on implementing the arrangements set out in its equality scheme to discharge its Section 75 statutory duties (the Section 75 Annual Progress Report).  The Section 75 annual progress report will be sent to the Equality Commission by 31 August each year and will follow any guidance on annual reporting issued by the Equality Commission.
27. We will also address Section 75 statutory duties in the NIAO Annual Report.
28. The latest Section 75 annual progress report is available on our website or by using the contact details at 2.4.
29. We will liaise with the Equality Commission to ensure that progress on the implementation of our equality scheme is maintained.

Action plan/action measures

30. The NIAO has developed an action plan to promote equality of opportunity and good relations and this is set out in Appendix 5.
31. The action measures contained in this action plan relate to our organisational functions and have been developed with consideration of the Section 75 categories.  The NIAO does not have an interface with the public and our policies are all internal.  We will monitor our progress on the delivery of our action measures on an ongoing basis, and update the action plan as necessary to ensure that it remains effective and relevant to our functions and work.
32. Our action plan will cover a period of up to three years (2021 – 2024) to align with our corporate and business planning cycle.  Implementation of the action measures will be incorporated into our business planning process.
33. We may consult on the action plan following to its submission to the Equality Commission and may also seek input from our stakeholders when reviewing the plan as per 2.12 above.
34. Action measures in the action plan will be specific, measurable, linked to achievable outcomes, realistic and time-bound, and include performance indicators and timescales for their achievement.
35. The NIAO will inform the Equality Commission of any changes or amendments to this action plan and will also include this information in its Section 75 annual progress report to the Commission.  This progress report will record progress made in implementing the Action Plan.
36. Once finalised, this action plan will be available by using the contact details above.  If you require this in an alternative format, please contact us on the details provided.

Chapter 3

Our arrangements for consulting

37. We recognise the importance of consultation in the implementation of our statutory equality duties.  We will consult on our equality scheme, action plan, equality impact assessments and other matters relevant to the Section 75 statutory duties.
38. We are committed to carrying out consultation in accordance with the following principles (as contained in the Equality Commission’s guidance ‘Section 75 of the Northern Ireland Act 1998 – A Guide for Public Authorities (April 2010)’).
39. All consultations will seek the views of those directly affected by the matter/policy, the Equality Commission, representative groups of Section 75 Categories, other public authorities, voluntary and community groups, our staff and their trades unions and such other groups who have a legitimate interest in the matter or policy, as appropriate.
40. Initially all consultees (see Appendix 2), as a matter of course, will be notified (by e-mail or post) of the matter/policy being consulted upon, to ensure they are aware of all consultations.  Thereafter, to ensure the most effective use of our and our consultees’ resources, we will take a targeted approach to consultation with those consultees that may have a particular interest in a matter/policy being consulted upon and to whom it is of particular relevance.  This may include, for example, regional, local, sectoral or thematic consultation.  The list of consultees is reviewed on a general basis at least annually and for specific purposes when a matter/policy needs to go out to consultation.
41. Consultation with all stakeholders will begin as early as possible. We will engage with affected individuals and representative groups to identify how best to consult or engage with them.  We will ask our consultees about their preferred consultation methods and give consideration to these, which could include:

• face-to-face meetings;
• focus groups;
• written documents with the opportunity to comment in writing;
• questionnaires;
• telephone consultations; or

• information/notification by e-mail with an opportunity to opt in/opt out of a consultation exercise.

  This list is not exhaustive and we may develop other additional methods of consultation more appropriate to key stakeholders and the matter being consulted upon.

42.  We will also consider the accessibility and format of each consultation method used in order to remove barriers to the consultation process.  Specific consideration will be given to how best to communicate with children and young people, people with disabilities (in particular people with learning disabilities) and minority ethnic communities.
43. We will liaise with representatives of young people, people with disabilities and minority ethnic communities and with others who have specialist knowledge in this area, as appropriate.  We will also take account of existing and developing good practice, including the Equality Commission’s guidance Let’s Talk Let’s Listen – Guidance for public authorities on consulting and involving children and young people (2008).
44. Information will be made available, on request, in alternative formats in a timely manner, usually within 20 working days.  If this cannot be facilitated, we will inform consultees of the reasons for this and provide a new estimated response timescale.   We will ensure that such consultees have sufficient time to respond.
45. Specific training will be provided to those facilitating consultations to ensure that they have the necessary skills to communicate effectively with consultees.
46. The consultation period will last for a minimum of twelve weeks to allow adequate time for groups to consult amongst themselves as part of the process of forming a view.  However, in exceptional circumstances when this timescale is not feasible (for example, implementing EU Directives or UK wide legislation, meeting health and safety requirements, addressing urgent public health matters or complying with court judgements), we may shorten the timescale to eight weeks or less before policy implementation takes place.  We may continue consultation thereafter and will take account of comments as part of our monitoring commitments (see 4.27-4.31).  Where, under these exceptional circumstances beyond NIAO’s control, we must carry out policy implementation immediately, we may consult following this in order to ensure that any impacts of the policy/policies are considered.
47. If a consultation exercise is to take place over a period when consultees are less able to respond, for example, over the summer or Christmas break, or if a policy under consideration is particularly complex, we will consider the feasibility of allowing a longer period for the consultation.
48. We are conscious that affected individuals and representative groups may have different needs.  We will take appropriate measures to ensure full participation in any meetings that are held, having considered, for example, the time of day; the appropriateness of the venue (particularly whether it can be accessed by those with disabilities); how the meeting is to be conducted; the use of appropriate language and whether an interpreter is necessary.
49. We will make all relevant information available to consultees to ensure meaningful consultation, including detailed information on the policy/ matter being consulted upon.
50. In making any decision with respect to a policy which has been or is planned to be implemented, we will take into account any assessment and consultation carried out in relation to that policy and any relevant quantitative and qualitative data.
51. We will provide feedback to consultees in a timely manner.  A feedback report will be prepared which includes summary information on the policy/matter consulted upon; as well as consultees’ comments and our consideration of and response to consultees’ input in a summary form.  The feedback will be provided in formats suitable to consultees. 
52. A list of our consultees is included at Appendix 2. 
53. Our consultee list is not exhaustive and is reviewed annually to ensure its ongoing relevance to our work.  We also welcome enquiries from any person/s or organisations wishing to be included in this list - please use our contact details to provide your contact details and have your areas of interest noted or have your name/details amended or removed.  Please also inform us at this stage if you would like information sent to you in a particular format or language.

Chapter 4

Our arrangements for assessing, monitoring and publishing the impact of policies

Arrangements for assessing the likely impact of policies adopted or proposed on the promotion of equality of opportunity

54. In the context of Section 75, ‘policy’ is very broadly defined and it covers all the ways in which we carry out or propose to carry out our functions in relation to Northern Ireland.  In respect of this equality scheme, the term policy is used for any (proposed/amended/existing) strategy; policy initiative; practice and/or decision, whether written or unwritten and irrespective of the label given to it, such as ‘draft’, or ‘pilot’.
55. In making any decision with respect to a policy adopted or proposed to be adopted, we take into account any assessment and consultation carried out in relation to the policy, as required by Schedule 9 9(2) of the Northern Ireland Act 1998.
56. We use the tools of screening and equality impact assessment (EQIA) to assess the likely impact of a policy on the promotion of equality of opportunity and good relations.  In carrying out these assessments, we will relate them to the intended outcomes of the policy in question and will also follow Equality Commission guidance:

• the guidance on screening, including the screening template, as detailed in the Commission’s guidance ‘Section 75 of the Northern Ireland Act 1998 – A Guide for Public Authorities (April 2010)’ and
• on undertaking an equality impact assessment as detailed in the Commission’s guidance ‘Practical guidance on equality impact assessment (February 2005)’.

Screening

57. The purpose of screening is to identify those policies which are likely to have an impact on equality of opportunity and good relations. 
58. Screening is completed at the earliest opportunity in the policy development/review process.  Policies which we propose to adopt will be subject to screening prior to implementation.  For more detailed strategies or policies that are to be put in place through a series of stages, we will screen at various stages during implementation.
59. The lead role in the screening of a policy is taken by the policy decision maker with authority to make changes to that policy.  However, screening may also involve other relevant NIAO staff, for example equality specialists and those who implement the policy.
60. The following questions are applied to all our policies as part of the screening process:

• What is the likely impact on equality of opportunity for those affected by this policy, for each of the Section 75 equality categories? Minor/Major/None
• Are there opportunities to better promote equality of opportunity for people within the Section 75 equality categories? Yes/No
• Are there opportunities, without prejudice to the equality of opportunity duty, to better promote good relations? Yes/No
• Is there an opportunity to better promote positive attitudes towards people with disabilities by altering the policy or working with others in government or the wider community? Yes/No
• Is there an opportunity to encourage people with disabilities to participate in public life by altering the policy or working with others in government or the wider community? Yes/No
• Are there opportunities to promote, by appropriate measures, mutual understanding between all linguistic groups and in particular the inclusion of respect, understanding and tolerance? Yes/No

61. In order to answer the screening questions, we gather all relevant qualitative and quantitative data and information and consider this in the context of the differing needs, experiences and priorities for each of the Section 75 equality categories.  Any screening decision will be informed by this evidence.
62. From a consideration of the answers to the screening questions set out above, one of three possible outcomes will result:
    • the policy is ‘screened in’ for equality impact assessment;
    • the policy is ‘screened out’ with mitigation (where a screening assessment reveals that a particular policy has an adverse impact on equality of opportunity/ good relations, a public authority must consider ways of delivering the policy outcomes in a way which will have a less adverse effect on the relevant Section 75 categories) or an alternative policy is proposed for adoption; orthe policy is ‘screened out’ without mitigation or an alternative policy proposed for adoption. 
63. If our screening concludes that the likely impact of a policy is ‘minor’ in respect of one or more of the equality of opportunity/good relations categories we may, on occasion and depending on the policy, decide to proceed with an EQIA.  If an EQIA is not to be conducted we will, nonetheless, consider measures which may mitigate the policy impact, as well as alternative policies that might better achieve the promotion of equality of opportunity/good relations.
64. Where we mitigate, we will outline in our screening template the reasons to support this decision together with the proposed changes, amendments or alternative policy.  This screening decision will be ‘signed off’ by the appropriate policy lead within NIAO.
65. If our screening concludes that the likely impact of a policy is ‘major’ in respect of one or more of the equality of opportunity/good relations categories, we will normally subject the policy to an EQIA.  This screening decision will be ‘signed off’ by the appropriate policy lead within NIAO.
66. If our screening concludes that the likely impact of a policy in respect of all of the equality of opportunity/good relations categories is ‘none’, we may decide to screen the policy out.  If a policy is ‘screened out’ as having no relevance to equality of opportunity/good relations, we will give details of the reasons for the decision taken.  This screening decision will be ‘signed off’ by the appropriate policy lead within NIAO.
67. As soon as possible following the completion of the screening process, the screening template, signed off and approved by the senior manager responsible for the policy, will be made available on our website and on request using the contact details above.
68. If a consultee raises a concern about a screening decision based on supporting evidence, we will take steps to review this decision.
69. We will also publish screening reports bringing together the results of individual policy screening work on a quarterly basis or when relevant.

Equality impact assessment

70. An equality impact assessment (EQIA) is a thorough and systematic analysis of a policy, whether that policy is formal or informal, and irrespective of its scope.  The primary function of an EQIA is to determine the extent of any impact of a policy upon the Section 75 categories and to determine if the impact is an adverse one.  It is also an opportunity to demonstrate the likely positive outcomes of a policy and to seek ways to more effectively promote equality of opportunity/good relations.
71. Once a policy is screened and screening has identified that an EQIA is necessary, we will carry this out in accordance with Equality Commission guidance as part of the policy development process.  This will be carried out before implementation.
72. Any EQIA will be subject to consultation at the appropriate stage(s), using the arrangements set out in Chapter 3.

Arrangements for publishing the results of the assessments of the likely impact of policies adopted or proposed on the promotion of equality of opportunity

73. We will make publicly available the results of our assessments (screening and EQIA) of the likely impact of our policies on the promotion of equality of opportunity/good relations.

What we publish

Screening reports

74. Our screening reports, published when relevant, will detail:
    • all policies screened by NIAO over the period;
    • screening decisions;
    • where applicable, a timetable for conducting EQIAs; and
    • a link to the completed screening template(s) on NIAO’s website.

Screening templates

75. Our arrangements for making these publically available are set out in Chapter 4.

Equality impact assessments

76. EQIA reports will be published once an Equality Impact Assessment has been completed and will include:
    • statement of the aim of the policy assessed;
    • data and information collected;
    • details of the assessment of impact(s);
    • consideration given to measures which might mitigate any adverse impact;
    • consideration given to alternative policies which might better achieve the promotion of equality of opportunity;
    • consultation responses;
    • the decision taken; and
    • future monitoring plans.

How and where we publish information

77. All the documents which we publish are accessible and can be made available in alternative formats on request – see Chapter 6.
78. The results of our assessments (screening reports and completed templates, the results of Equality Impact Assessments) will be available on our website or by using the contact details set out in Chapter 2.
79. In addition, screening reports (electronically or in hard copy on request if more suitable for recipients) which include all policies screened over a 3 month period, will be available on the NIAO website on a quarterly basis.
80. Where appropriate, we may inform the general public about the availability of this material through communications such as the internet and press releases.
81. Monitoring can assist us to deliver better public services and continuous improvements.  Monitoring Section 75 information involves the processing of sensitive personal data (data relating to the racial or ethnic origin of individuals, sexual orientation, political opinion, religious belief, etc.). In order to carry out monitoring in a confidential and effective manner, the NIAO will follow guidance from the Information Commissioner’s Office and the Equality Commission.
82. We monitor any adverse impact on the promotion of equality of opportunity of policies we have adopted.  We are also committed to monitoring more broadly to identify opportunities to better promote equality of opportunity and good relations in line with Equality Commission guidance.
83. The systems which we have established to monitor the impact of policies and identify opportunities to better promote equality of opportunity and good relations involve:
    • the collection, collation and analysis of existing relevant quantitative and qualitative data across the Section 75 equality categories on an ongoing basis;
    • an audit of existing information systems within one year of approval of this equality scheme, to identify the extent of current monitoring and take action to address any gaps, in order to have the necessary information on which to base decisions; and
    • undertaking or commissioning new data if necessary.
84. If over a two-year period monitoring and evaluation show that a policy results in greater adverse impact than predicted, or if opportunities arise which would allow for greater equality of opportunity to be promoted, we will ensure that the policy is revised to achieve better outcomes for relevant equality groups.
85. We will review EQIA monitoring information on an annual basis, while other monitoring information is reviewed on an ongoing basis.

Arrangements for publishing the results of our monitoring

86. Schedule 9 4(2)(d) of the Act requires us to publish the results of the monitoring of adverse impacts of policies we have adopted.  The results of our policy monitoring are published as follows:
    • EQIA monitoring information is published as part of our Section 75 Annual Progress Report; and
    • we will make publicly available the outcome of any monitoring undertaken to measure the adverse impact of policies.
87. All information published is accessible on our website and can be made available in alternative formats on request and in a timely manner (please see below at Chapter 6) using the contact details in Chapter 2.

Chapter 5

Staff Training

Commitment to staff training

88. We recognise that awareness raising and training play a crucial role in the effective implementation of our Section 75 duties.
89. The C&AG wishes to positively communicate his commitment to the Section 75 statutory duties, both internally and externally and will ensure that our commitment to the Section 75 statutory duties is made clear in relevant NIAO publications.
90. We will review our existing training arrangements and will draw up a detailed training programme for all staff.

Training objectives

91. The NIAO’s training for its staff aims to achieve the following objectives:
    • to raise awareness of the provisions of Section 75 of the Northern Ireland Act 1998, our equality scheme commitments and the particular issues likely to affect people across the range of Section 75 categories, to ensure that our staff fully understand their role in implementing the scheme;
    • to provide those staff involved in the assessment of policies (screening and EQIA) with the necessary skills and knowledge to do this work effectively;
    • to provide those staff who deal with complaints in relation to compliance with our equality scheme with the necessary skills and knowledge to investigate and monitor complaints effectively.
    • to provide those staff involved in consultation processes with the necessary skills and knowledge to do this work effectively; and
    • to provide those staff involved in the implementation and monitoring of the effective implementation of the NIAO’s equality scheme with the necessary skills and knowledge to do this work effectively.

Awareness raising and training arrangements

92. The following arrangements will be taken forward to ensure that all our staff and Non-Executive Members are aware of, and understand our equality obligations:
    • we will develop a summary of this equality scheme and make it available to all staff;
    • we will provide access to copies of the full equality scheme for all staff and ensure that any queries or questions of clarification from staff are addressed effectively;
    • the Section 75 statutory duties form part of induction for all new staff and Non-Executive Members;
    • focused training is provided for key staff within the NIAO who are directly engaged in taking forward the implementation of our equality scheme commitments (for example those involved in research and data collection; policy development; policy screening; conducting EQIAs; consultation; monitoring and evaluation);
    • where appropriate, training will be provided to ensure that all staff are aware of the issues experienced by the range of Section 75 groups; and
    • when appropriate and on an ongoing basis, arrangements will be made to ensure that all staff are kept up to date with Section 75 developments.
93. Training and awareness raising programmes will, where relevant, be developed in association with the appropriate Section 75 groups and our staff.  In order to share resources and expertise, the NIAO will, where appropriate, work closely with other bodies and agencies in the development and delivery of training.

Monitoring and evaluation

94. Our training programme is subject to the following monitoring and evaluation arrangements:
    • we evaluate the extent to which all participants in this training programme have acquired the necessary skills and knowledge to achieve the set objectives; and
    • the extent to which training objectives have been met will be reported on as part of the Section 75 Annual Progress Report sent to the Equality Commission.

Chapter 6

Our arrangements for ensuring and assessing public access to information and services we provide

95. The NIAO is committed to ensuring that the information we disseminate and the services we provide are fully accessible to all parts of the community in Northern Ireland.  We will keep our arrangements under review to ensure that this remains the case.
96. We are aware that some groups will not have the same access to information as others, in particular:
    • people with sensory, learning, communication and mobility disabilities may require printed information in other formats;
    • members of minority ethnic groups, whose first language is not English, may have difficulties with information provided only in English; and
    • children and young people may not be able to fully access or understand the information.

Access to information

97. To ensure equality of opportunity in accessing information, we will provide information in alternative formats on request, where reasonably practicable.  Where the exact request cannot be met we will ensure a reasonable alternative is provided. Alternative formats may include Easy Read; Braille; audio formats; large print or minority languages to meet the needs of those for whom English is not their first language.
98. We will respond to requests for information in alternative formats in a timely manner, usually within 20 working days.  In addition, we will continue to monitor our arrangements for information provision and make any necessary improvements to ensure better public access to information.
99. In terms of arrangements for providing information to young people, older people, low income families and disability and minority ethnic communities, we will liaise with representatives and take account of existing and developing good practice (see Chapter 3).
100.  In disseminating information on our equality scheme generally, we may make use of the internet and media releases.

Access to services

101. The NIAO is committed to ensuring that all of our services are fully accessible to everyone in the community across the Section 75 categories.  We also adhere to the relevant provisions of current anti-discrimination legislation.

Assessing public access to information and services

102. We will take appropriate steps to monitor across all our functions in relation to access to information and services on an ongoing basis, to ensure that equality of opportunity and good relations are promoted.

Chapter 7

Timetable for measures we propose in this equality scheme

103. Appendix 3 outlines our timetable for the measures which we have proposed within this equality scheme. These will also be incorporated into our business planning processes.
104. This timetable is distinct from, and in addition to, our commitment to develop action plan(s)/action measures to specifically address inequalities and thereby further promote equality of opportunity and good relations, which has been set out at Appendix 5.  Further information on these action measures can be found in 2.11-2.17.

Chapter 8

Our Complaints Procedure

105. The NIAO is responsive to the views of members of the public.  We will endeavour to resolve all complaints made to us.
106. Schedule 9 paragraph 10 of the Act refers to complaints.  A person can make a complaint to a public authority if the complainant believes he or she may have been directly affected by an alleged failure of the authority to comply with its approved equality scheme.
107. If the complaint has not been resolved within a reasonable timescale, the complaint can be brought to the Equality Commission.
108. A person wishing to make a complaint that the NIAO has failed to comply with its approved equality scheme should refer to the ‘Contact Us’ section on our website or use the contact details set out in Chapter 2.
109. We will, in the first instance, acknowledge receipt of each complaint within 5 working days.
110. We will carry out an internal investigation of the complaint and respond substantively to the complainant within 1 month of the date of receiving the letter of complaint.  Under certain circumstances, if the complexity of the matter requires a longer period, the period for response to the complainant may be extended to 2 months.  In those circumstances, the complainant will be advised of the extended period within 1 month of making the complaint.
111. During this process the complainant will be kept fully informed of the progress of the investigation into the complaint and of any outcomes. The NIAO will provide any reasonable support required by the complainant in pursuit of their complaint. This may include interpreter support, specialist transport costs or other assistance to allow the complainant full access to the process
112. In any subsequent investigation by the Equality Commission, the NIAO will co-operate fully, providing access in a timely manner to any relevant documentation that the Equality Commission may require.
113. Similarly, the NIAO will co-operate fully with any investigation by the Equality Commission under sub-paragraph 11(1)(b) of Schedule 9 to the Northern Ireland Act 1998.
114. The NIAO will make every effort to implement promptly and in full any recommendations arising out of any Commission investigation.

Chapter 9

Publication of our equality scheme

115. The NIAO’s equality scheme is available free of charge in print form and alternative formats, using the contact details set out in 2.4.
116. Our equality scheme is also available on our website.
117. The following arrangements are in place for the publication of our equality scheme in a timely manner to ensure equality of access:
     • we will make every effort to communicate widely the existence and content of our equality scheme, which may include using the internet and press releases;
     • we will send an electronic link to our approved equality scheme to those representative organisations on our consultee list, while other consultees without e-mail will be notified by letter that the scheme is available on request;
     • our equality scheme will be available in alternative formats on request .  Alternative formats could include Easy Read; Braille; audio formats; large print or minority languages to meet the needs of those who are not fluent in English.  We will respond to requests for the equality scheme in alternative formats in as timely a manner as possible.
118. For a list of our consultees please see Appendix 2 of the equality scheme, visit our website or use the contact details set out in Chapter 2.

Chapter 10

Review of our equality scheme

119. As required by Schedule 9 paragraph 8(3) of the Northern Ireland Act 1998, we will conduct a thorough review of this equality scheme.  This review will take place either within five years of submission of this scheme to the Equality Commission or within a shorter timescale to allow alignment with the review of other planning cycles.
120. The review will evaluate the effectiveness of the NIAO scheme in relation to the implementation of the Section 75 statutory duties relevant to our functions in Northern Ireland.
121. In undertaking this review, we will follow any guidance issued by the Equality Commission.  A report of this review will be made public on the NIAO website and sent to the Equality Commission.

Appendix 1: Example groups relevant to the Section 75 categories for Northern Ireland purposes

Please note this list is for illustration purposes only, it is not exhaustive.

Religious belief (for the purposes of Section 75, the term ‘religious belief’ is the same definition as that used in the Fair Employment & Treatment (NI) Order 1998.  Therefore, “religious belief” also includes any perceived religious belief (or perceived lack of belief) and, in employment situations only, it also covers any ‘similar philosophical belief’):

• Buddhist; 
• Catholic; 
• Hindu; 
• Jewish; 
• Muslim; 
• people of no religious belief; 
• Protestant, 
• Sikh; 
• Other faiths.

Political Opinion:

• Nationalist generally
• Unionists generally
• Members/supporters of other political parties.

Racial Group:

• Black people
• Chinese
• Indians
• Pakistanis
• People of mixed ethnic background
• Polish; Roma
• Travellers
• White people

Men and women generally:

• Men (including boys)
• Trans-gendered people
• Women (including girls)

Marital status:

• Civil partners or people in civil partnerships
• Divorced people
• Married people
• Separated people
• Single people
• Widowed people.

Age:

• Children and young people
• Older people.

Persons with a disability:

• Persons with disabilities as defined by the Disability Discrimination Act 1995.

Persons with dependants:

• Persons with personal responsibility:

  • for the care of a child
  • for the care of a person with a disability
  • for the care of a dependant older person.

Sexual orientation:

• Bisexual people
• Heterosexual people
• Gay or lesbian people.

Appendix 2: List of potential consultees

• Age NI

• An Munia ToberBritish Deaf Association NI

• Bryson Intercultural

• Carers NI

• Church of Ireland

• Coalition on Sexual Orientation

• Committee on the Administration of Justice

• Community Relations Council

• Department of Agriculture, Environment and Rural Affairs

• Department for Communities

• Department of Education

• Department for the Economy

• Department of Finance

• Department of Health

• Department for Infrastructure

• Department of Justice

• Disability Action

• East Belfast Community Development Agency

• Equality Commission for Northern Ireland

• The Executive Office

• First Division Association

• Gingerbread

• Irish Congress of Trade Unions (Northern Ireland Committee)

• Local Government Staff Commission for NI

• Mencap

• Methodist Church

• NI Council for Ethnic Minorities

• NI Council for Voluntary Action

• NI Human Rights Commission

• NI Political Parties

• NI Public Service Alliance

• Presbyterian Church in Ireland

• Roman Catholic Church

• Royal National Institute for the Blind (Northern Ireland)

• Royal National Institute for Deaf People

• Rural Community Network

• West Belfast Economic Forum

• Women’s Aid Federation Northern Ireland

• Youth Council for Northern Ireland

This consultee list is not exhaustive and will be reviewed annually to ensure its relevance.

Appendix 3 - Timetable for measures proposed in our equality scheme

Lead Responsibility for implementing these Measures lies with the Corporate Services Directorate

Appendix 4 - Glossary of Terms

Action Plan: A Plan which sets out actions a public authority will take to implement its Section 75 statutory duties.  It is a mechanism for the realisation of measures to achieve equality outcomes for the Section 75 equality and good relations categories.

Action Measures and Outcomes: Specific measures to promote equality and good relations for the relevant Section 75 and good relations categories, linked to achievable outcomes, which should be realistic and timely.

Adverse Impact: Where a Section 75 category has been affected differently by a policy and the effect is less favourable, it is known as adverse impact.  If a policy has an adverse impact on a Section 75 category, a public authority must consider whether or not the adverse impact is unlawfully discriminatory.  In either case a public authority must take measures to redress the adverse impact, by considering mitigating measures and/or alternative ways of delivering the policy.

Article 55 Review: Under the Fair Employment and Treatment (NI) Order 1998, all registered employers must conduct periodic reviews of the composition of their workforces and of their employment practices for the purposes of determining whether members of the Protestant and Roman Catholic communities are enjoying, and are likely to continue to enjoy, fair participation in employment in each employer’s concern.  These reviews, which are commonly known as ‘Article 55 Reviews’, must be conducted at least once every three years.

Audit of Inequalities: An audit of inequalities is a systematic review and analysis of inequalities which exist for service users and those affected by a public authority’s policies.  An audit can be used by a public authority to inform its work in relation to the Section 75 equality and good relations duties. It can also enable public authorities to assess progress on the implementation of the Section 75 statutory duties, as it provides baseline information on existing inequalities relevant to a public authority’s functions.

Consultation: In the context of Section 75, consultation is the process of asking those affected by a policy (i.e. service users, staff, the general public) for their views on how the policy could be implemented more effectively to promote equality of opportunity across the 9 categories.  Different circumstances will call for different types of consultation.  Consultations could, for example, include meetings, focus groups, surveys and questionnaires.

Discrimination:The anti-discrimination laws prohibit the following forms of discrimination - direct discrimination; indirect discrimination; disability discrimination; victimisation and harassment, which can been defined as follows:

• Direct discrimination: Where a public authority treats a person less favourably than it treats (or, would treat) another person, in the same or similar circumstances, on one or more of the statutory non-discrimination grounds. A decision or action that is directly discriminatory will normally be unlawful unless: (a) in an age discrimination case, the decision can be objectively justified, or (b) in any other case, the public authority can rely on a statutory exception that permits it – such as a genuine occupational requirement exception; or, a positive action exception which permits an employer to use “welcoming statements” or to take other lawful positive action to encourage participation by under-represented or otherwise disadvantaged groups
• Indirect discrimination: This generally occurs where a public authority applies to all persons a particular provision, criterion or practice, but which is one that has the effect of placing people who share a particular equality characteristic (e.g. the same sex, or religious belief, or race) at a particular disadvantage compared to other people.  A provision, criterion or practice that is indirectly discriminatory will normally be unlawful unless (a) it can be objectively justified, or (b) the public authority can rely on a statutory exception that permits it
• Disability discrimination: In addition to direct discrimination and victimisation and harassment, discrimination against disabled people may also occur in two other ways:
  • Disability-related discrimination generally occurs where a public authority, without lawful justification, and for a reason which relates to a disabled person’s disability, treats that person less favourably that it treats (or, would treat) other people to whom that reason does not (or, would not) apply
  • Failure to comply with a duty to make reasonable adjustments: One of the most notable features of the disability discrimination legislation is that in prescribed circumstances it imposes a duty on employers, service providers and public authorities to take such steps as are reasonable to remove or reduce particular disadvantages experienced by disabled people in those circumstances
• Victimisation: This generally occurs where a public authority treats a person less favourably than it treats (or, would treat) another person, in the same or similar circumstances, because the person has previously exercised his/her rights under the anti-discrimination laws, or has assisted another person to do so.  Victimisation cannot be justified and is always unlawful
• Harassment: This generally occurs where a person is subjected to unwanted conduct that is related to a non-discrimination ground with the purpose, or which has the effect, of violating their dignity or of creating for them an intimidating, hostile, degrading, humiliating or offensive environment.  Harassment cannot be justified and is always unlawful.

Equality Impact Assessment: The mechanism underpinning Section 75, where existing and proposed policies are assessed in order to determine whether they have an adverse impact on equality of opportunity for the relevant Section 75 categories.  Equality impact assessments require the analysis of both quantitative (experiences of individuals) and qualitative data (numbers derived from a population in general or samples of that population).

Equality of Opportunity: This is the prevention, elimination or regulation of discrimination between people on grounds of characteristics including sex, marital status, age, disability, religious belief, political opinion, dependants, race and sexual orientation. The promotion of equality of opportunity entails more than the elimination of discrimination.  It requires proactive measures to be taken to secure equality of opportunity between the categories identified under Section 75.

Good Relations: Good relations can be said to exist where there is: 

• a high level of dignity, respect and mutual understanding 
• an absence of prejudice, hatred, hostility or harassment 
• a fair level of participation in society. 

Good relations means, in particular, having regard to the desirability of a) tackling prejudice and b) promoting understanding.

Mitigation of Adverse Impact: Where an equality impact assessment reveals that a particular policy has an adverse impact on equality of opportunity, a public authority must consider ways of delivering the policy outcomes which have a less adverse effect on the relevant Section 75 categories; this is known as mitigating adverse impact

Monitoring: Monitoring consists of continuously scrutinising and evaluating a policy to assess its impact on the Section 75 categories.  Monitoring must be sensitive to the issues associated with human rights and privacy.  Public authorities should seek advice from consultees and Section 75 representative groups when setting up monitoring systems. Monitoring consists of collecting relevant information and evaluating policies.  It is not solely about the collection of data and can also take the form of regular meetings and reporting of research undertaken.  Monitoring also provides the data for the next cycle of policy screening.

Northern Ireland Act 1998: The Northern Ireland Act, implementing the Good Friday Agreement, received Royal Assent on 19 November 1998.  Two of the relevant references are Schedule 9 and Section 75:

• Schedule 9: Schedule 9 of the Northern Ireland Act 1998 sets out detailed provisions for the enforcement of the Section 75 statutory duties, including an outline of what should be included in an Equality Scheme
• Section 75: Section 75 of the Northern Ireland Act provides that each public authority is required, in carrying out its functions relating to Northern Ireland, to have due regard to the need to promote equality of opportunity between:
• persons of different religious belief, political opinion, racial group, age, marital status and sexual orientation;
• men and women generally;
• persons with a disability and persons without; and
• persons with dependants and persons without.

Without prejudice to these obligations, each public authority in carrying out its functions relating to Northern Ireland must also have regard to the desirability of promoting good relations between persons of different religious belief, political opinion or racial group.

Screening: This is the procedure for identifying which policies will be subject to equality impact assessment, and how these equality impact assessments will be prioritised.  The purpose of screening is to identify the policies which are likely to have a minor/major impact on equality of opportunity so that greatest resources can be devoted to improving them through a process of systematic review.

Appendix 5 - NIAO Action Plan to promote Equality of Opportunity and Good Relations

The Northern Ireland Audit Office (NIAO) has had an Equality Scheme in place since 2003.  The scheme has provided a sound framework to mainstream equality of opportunity and good relations into policy making.  Given the focus the Office has placed on its equality obligations over the past number of years, an audit of inequalities has not identified any areas of major concern. However, we consider that there may be some scope to further or better discharge our Section 75 statutory duties.  Areas of specific focus have been incorporated in this Action Plan, which is aligned with the Office’s corporate and business planning cycle, and will be flexible, adaptable and responsive to changing circumstances.  The action measures will be progressed alongside the broader commitments in our Equality Scheme, including the measures set out in Appendix 3 of the Scheme.

The Comptroller and Auditor General (C&AG) is an Officer of the Assembly and his responsibility, under legislation, is to report the results of their work to the Northern Ireland Assembly. Their functions are to:

• authorise the issue of money from the Northern Ireland Consolidated Fund to enable Northern Ireland Departments to meet their necessary expenditure and ensure that there are adequate arrangements for the collection of revenue; and

• carry out the external audit of central government bodies in Northern Ireland, including Northern Ireland departments and their executive agencies, and a wide range of other public sector bodies including health and social care bodies and other non departmental public bodies.

A member of their staff is the Local Government Auditor with responsibility for the external audit of Local Government Bodies.  Further information on the role of the C&AG and the NIAO can be found at www.niauditoffice.gov.uk or through using the contact details below.

Brian O’Neill

Director of Corporate Services

Northern Ireland Audit Office, 106 University Street, Belfast, BT71EU

028 9025 4323

equality@niauditoffice.gov.uk

The Office’s audit functions are carried out in accordance with legislation and in compliance with professional standards, including International Auditing Standards.  Any impact of these on equality of opportunity and good relations has been and will continue to be considered through the policy screening processes.  The C&AG does not provide services directly to the public nor has he a remit in terms of assessing how well bodies are meeting the requirements of Section 75 (a role which is undertaken by the Equality Commission). That said, equality issues may be relevant to topics examined by the Office.  The bodies audited by NIAO are subject to Section 75 and the performance of these bodies against their Section 75 responsibilities may be relevant to our judgement about the economy, efficiency and effectiveness with which they have used their resources.  Accordingly, the Office recognises that a key way in which audit can make a contribution to promoting equality of opportunity is through its programme of work, particularly its public reporting programme which is determined by the C&AG.  The Office has carried out a number of studies impacting on Section 75 categories.  These reports have been published and are available on the NIAO website (www.niauditoffice.gov.uk).

In taking forward our equality obligations, employment related matters and communication will continue to be areas of particular focus.  These are our priorities in this Action Plan and related measures have been scheduled over the period 2021-2026.  We will review and update the plan over the life time of this Equality Scheme and annually via the Section 75 progress report, and incorporate further action measures as required.  Ongoing monitoring will be considered to allow for measurement and reporting of progress on the delivery of the Plan.

All 9 categories under Section 75 will benefit from the Action Measures.  All Action measures relate to Duties 1 and 2 of Section 75.

Any queries on the Action Plan should be submitted using the contact details above.

Area of Focus: Communications - NIAO Communications and Engagement Strategy

Inequality Identified: Under the “The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations (WMAA) 2018”, we are required to make our website compatible with the equivalent Web Content Accessibility Guidelines (WCAG) 2.1AA.  We are also required to publish an accessibility statement to explain, among other things, which parts of the website(s) or app(s) are not accessible with a plan to comply or explain.

Action Measure Developed: We are working closely with IT Assist in the development of our new website.  This project, which is being piloted as part of a wider public sector programme, will address the issue of accessibility. Following the audit of our website by an accessibility auditor on 28 October 2020, we developed and published a website statement in keeping with legislative requirements. Many of the issues raised in the review relate to the underlying content management system (CMS) which will be addressed in the development of our new website.  Contents issues were addressed through a thorough review of each of our webpages. The Accessibility Statement has been updated to reflect the findings and proposals arising out of the audit. We will continue to review the statement, and are working towards addressing the accessibility issues highlighted in the development of the new website.

Timescale: 31 March 2022

Performance Indicator: Communication systems are compliant with and relevant WMAA Regulations.

Area of Focus: Skills Training and Skills Development - NIAO Learning and Development Strategy implementation

Inequality Identified: An office-wide strategic review of learning and development has been conducted to ensure a co-ordinated and structured approach to training and development of staff, encompassing equality of opportunity

Action Measure Developed: Implementation of the Corporate Learning and Development Strategy through annual training plans to ensure equality of opportunity.

Timescale: Training provided as required in accordance with requirements

Performance Indicator: Continuing review and Implementation of a comprehensive and balanced Learning and Development Strategy and associated annual training plans that are compliant with NIAO’s equality responsibilities.

Area of Focus: Skills Training and Skills Development - Staff awareness of equality and diversity issues

Inequality Identified: Increase awareness is required of equality and diversity issues

Action Measure Developed:

• Improve equality and diversity training
• Induction training
• Manager training e.g. Managing Employees with Mental Health concerns
• Regular employee training
• Ensure employees are aware of and regularly demonstrate what is expected of them in their role in relation to commitment and promotion of equality and diversity
• Managers encouraged to discuss equality & diversity as part of performance appraisal process.

Timescale: Training provided as required in accordance with requirements

Performance Indicator: Managers and staff have increased understanding of Equality and Diversity issues, fostering an inclusive culture and eliminating discrimination, victimisation and harassment

Area of Focus: Skills Training and Skills Development - Dignity at Work

Inequality Identified: Maintain a list of staff trained as Dignity at Work advisers, which will encompass many equality issues.

Action Measure Developed: Review list annually to have a minimum of 4 trained Dignity at Work Advisers.

Timescale: December 2022

Performance Indicator: Specifically trained staff to be the first port of call on dignity at work issues

Area of Focus: Skills Training and Skills Development - Investors in People

Inequality Identified: Continue to develop as an organisation and prepare for future challenges.

Action Measure Developed: Action plan to improve performance through management and development of NIAO staff.

Timescale: 31 March 2022

Performance Indicator: 

Area of Focus: General Employment Related Matters - Review of NIAO HR Policies

Inequality Identified: While this exercise is necessary from a business perspective, it is also an opportunity to identify if there is scope to further or better discharge our Section 75 statutory duties.

Action Measure Developed: A review of HR policies to identify gaps, updates required and policies to be prioritised.

Timescale: As and when required

Performance Indicator: Policies compliant with NIAO equality obligations.

Area of Focus: Recruitment and Selection - Selection criteria and process

Inequality Identified: Ensure that all recruitment and selection activities, including internal promotion and talent management, continue to promote equality of opportunity and attract more interest from under-represented groups.

Action Measure Developed: 

• Ensure all recruitment adverts and role profiles only contain the necessary skills and abilities required for the vacancy, to ensure equality of opportunity.
• Ensure that all selection methods are objective and measurable
• Ensure balanced panels as far as possible
• Ensure interview panel members receive diversity and equality training regularly.
• Analyse Fair employment returns and compare to the makeup of NI society

Timescale: As and when required

Performance Indicator: NIAO recruitment and selection procedures are compliant with equality obligations