Information Commissioner’s Office

Public Authority Statutory Equality and Good Relations Duties

Annual Progress Report 2018-2019

Contact:

Section 75 of the NI Act1998 and Equality Scheme

Name: Michael Collins

Telephone: 01625 545 705

Email: Michael.collins@ico.org.uk

Section 49A of the DisabilityDiscrimination Act 1995 andDisability Action Plan

As above X

Name:

Telephone:

Email:

Documents published relating to our Equality Scheme can be found at:

https://ico.org.uk/about-the-ico/our-information/equality-and-diversity/

Signature:

This report has been prepared using a template circulated by the Equality Commission.

It presents our progress in fulfilling our statutory equality and good relations duties, and implementing Equality Scheme commitments and Disability Action

Plans.

This report reflects progress made between April 2018 and March 2019

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PART A – Section 75 of the Northern Ireland Act 1998 and Equality Scheme

Section 1: Equality and good relations outcomes, impacts and good practice

1 In 2018-19, please provide examples of key policy/service delivery developments made by the public authority in this reporting period to better promote equality of opportunity and good relations; and the outcomes and improvements achieved.

Please relate these to the implementation of your statutory equality and good relations duties and Equality Scheme where appropriate.

The Information Commissioner's Office (ICO) is an independent authority set up to

uphold information rights in the public interest, promoting openness by public bodies

and data privacy for individuals.

Our Mission To uphold information rights for the UK public in the digital age.

Our Vision

To increase the confidence that the UK public have in organisations that process

personal data and those which are responsible for making public information available.

Strategic goals

1. To increase the public’s trust and confidence in how data is used and made available.

2. Improve standards of information rights practice through clear, inspiring and targeted engagement and influence.

3. Maintain and develop influence within the global information rights regulatory community.

4. Stay relevant, provide excellent public service and keep abreast of evolving technology.

5. Enforce the laws we help shape and oversee. 6. To be an effective and knowledgeable regulator for cyber-related privacy issues.

Our Values

Ambitious – Working boldly, ready to test boundaries and take advantage of new

opportunities; working with a sense of genuine urgency, continuously improving when

striving to be the very best we can be.

Collaborative – Working towards achieving our goals, supporting one another whilst

seeking and sharing information and expertise and working effectively with a range of

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partners to achieve our collective objectives.

Service focused – Working impartially and ethically to provide excellent services –

continuously innovating to remain relevant to the environment we regulate.

The legislation we regulate

Until 25 May 2018, the Data Protection Act 1998 (DPA 1998) was in place and was

therefore the data protection legislation the ICO regulated during the start of 2018-19.

As of 25 May 2018 the new Data Protection Act 2018 (DPA 2018) and the General Data

Protection Regulation (GDPR) both commenced, superseding the duties and obligations

under the DPA 1998. The DPA 2018 and the GDPR built on and enhanced individuals’

rights beyond DPA 1998, including the right to know what information is held about

them and the right to correct information that is wrong. It also obliges organisations to

manage the personal information they hold in an appropriate way.

The Freedom of Information Act 2000 (FOIA) gives people a general right of access to

information held by most public authorities. Aimed at promoting a culture of openness

and accountability across the public sector, it enables a better understanding of how

public authorities carry out their duties, why they make the decisions they do and how

they spend public money.

The Environmental Information Regulations 2004 (EIR) provide an additional means of

access to environmental information. The EIR cover more organisations than the FOIA,

including some private sector bodies, and have fewer exemptions.

The Privacy and Electronic Communications Regulations 2003 (PECR) regulate the use

of electronic communications for the purpose of unsolicited marketing to individuals and

organisations, including the use of cookies.

The Network and Information Systems Regulations 2018 (NIS) are derived from the

European NIS Directive, which establishes a common level of security for network and

information systems. These systems play a vital role in the economy and wider society,

and NIS aims to address the threats posed to them from a range of areas, most notably

cyber-attacks.

The Infrastructure for Spatial Information in the European Community Regulations

2009 (INSPIRE) give the Information Commissioner enforcement powers in relation to

the pro-active provision by public authorities of geographical or location based

information.

The Re-use of Public Sector Information Regulations 2015 (RPSI) gives the public the

right to request the re-use of public sector information and details how public bodies can

charge for re-use and license the information. The ICO deals with complaints about how

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public bodies have dealt with requests to re-use information.

The Investigatory Powers Act 2016 (IPA) imposes duties on communications service

providers in respect of the retention of communications data for third party

investigatory purposes where they have been issued with a notice from the Secretary of

State. The Information Commissioner has a duty to audit the security, integrity and

destruction of that retained data.

The Electronic Identification and Trust Services for Electronic Regulations 2016 (eIDAS)

sets out rules for the security and integrity of trust services including electronic

signatures, seals, time stamps and website authentication certificates. The ICO has a

supervisory role towards organisations providing these trust services, including being

able to grant qualified status to providers who demonstrate compliance with certain

areas of the regulations and the ability to take enforcement action.

The ICO has a regional office in Northern Ireland. Its role is set out below:

• To develop ICO’s presence within Northern Ireland by engaging with local stakeholders.

• To foster awareness of information rights law and ICO guidance. • To provide a local enquiry and advice service on information rights law for

organisations and individuals. • To identify local priorities and influence policy making within Northern

Ireland. • To contribute to the formulation of ICO guidance including by raising

awareness of regional policy issues, local sensitivities and needs • To undertake FOI casework alongside the team in our Head Office, primarily

relating to public authorities based within Northern Ireland. • To support regulatory action being taken in Northern Ireland. • To comply with statutory equality duties

Our Approach to Equality: Equality and Diversity are important fundamental issues for the ICO and underpin all of our work. We have set up an Equality and Diversity Committee, which includes senior staff and colleagues from across the organisation which meets on a regular basis to address equality issues and act to mainstream equality across the organisation and across the differing jurisdictions in the UK. The principle driving this is one of inclusiveness. We aim to ensure that all members of society have awareness of, and access to, their information rights and receive appropriate protection if their rights are infringed. We are committed to promoting equality and diversity in all we do. We want to eliminate barriers that prevent people accessing our services or enjoying employment opportunities within the ICO. We are committed to developing our staff and to fair and inclusive employment practices. We will work proactively to make sure that there are no restrictions to building and developing a diverse workforce.

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We provide our staff with a work environment and IT systems which help meet a range of needs; including accessible offices and IT systems, flexible and part-time working (to help work-life balance) and the provision of occupational health services. We also aim to recruit from a range of backgrounds and take the applicant anonymous approach when assessing candidates for employment.

At strategic level The Information Commissioner’s Office (the ICO) equality objectives are regularly assessed and reviewed in changing environments e.g. Brexit and to make them clearer and help to better define goals and reporting of outcomes. We have developed Equality Objectives which will help us take forward equality and diversity matters as a regulator, service provider and employer.

Our Equality Objectives during 2018-19:

Our equality objectives are driven from two strategic directives that guide our corporate strategy. These are; External: “To extend the ICO’s reach so that a wider range of individual and organisational users are aware of and able to access our services”. Internal: “To mainstream equality understanding and skills within our workforce in order to improve employee experience and our capacity to meet diverse user needs”. We put equality and diversity at the heart of everything and detail these equality objectives further into the following: Spreading knowledge and taking action We will raise awareness of information rights across the community and take action to ensure that organisations fulfil their obligations. We will have particular focus on groups and sectors where knowledge gaps may cause information rights inequalities or vulnerabilities. We will consider equality and diversity issues when prioritising our action as a regulator. Accessible Services Our services and information will be accessible for users and potential users of our services, and we will provide our staff with the skills and knowledge they need to provide high quality services for all. We will try to anticipate customer needs and we will take action to remove barriers to our services when possible. Encouraging others We will use our status as a regulator, advisory body and purchaser of services to influence improvements in equality by other organisations and across society. Employer Our workplaces and practices will be accessible, flexible, fair and inclusive. We will value the diversity, skills, backgrounds and experience of our people, enabling them to perform to their best in a welcoming and supportive environment. These objectives aim to ensure that the ICO is inclusive, accessible and diverse as a regulator, service provider and employer. This will help to ensure that all members of society have awareness of, and access to, their information rights and receive appropriate protection if their rights are infringed.

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Our Equality and Diversity Committee oversees our efforts to provide an increasingly

accessible service. We have reviewed the role of this Committee, to ensure that, with

the increased size of the organisation, it continues to ensure that we embed equality and

diversity into everything we do, as a regulator, a service provider and employer. The

Committee provides support and expertise, but it is important that it is not regarded as

the main ‘owner’ for equality initiatives. We wish to embed equality and diversity in the

operational work of the ICO with local accountability resting with relevant departmental

and project / activity leads, with involvement from staff across the organisation.

These equality objectives have been updated for 2019/20, and during the year we will

also be reviewing our Equality and Diversity governance structure. Our intention is to

implement a series of network groups which enable staff with various characteristics,

backgrounds and interests to come together to help inform our approach to equality

issues.

Our Equality and Diversity Committee will then transform into a forum with links to our

Senior Leadership Team. The forum will enable the network groups to feedback and help

us to improve the connection of our diversity groups to strategic decision making.

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2 Please provide examples of outcomes and/or the impact of equality action plans/ measures in 2018-19 (or append the plan with progress/examples identified).

This section of the report will provide an overview of how the ICO contributes to a more equal society, particularly through our remit as the regulator of information rights. Where helpful, we provide illustrative examples of the types of activity that are being delivered within key business areas.

Intrinsic to our strategic goals set out in the previous section is a core mission to ensure that information rights are accessible and understood by all members of the community.

Our enforcement activity is geared towards protecting the public from misuse and abuse of the law, and is frequently centred on the protection of vulnerable and protected groups.

For example, our work to protect younger people, such as the Age Appropriate Design Code, seeks to safeguard some of our community’s most vulnerable people at a time when the advancement of technology means that privacy can be impacted upon in ways which were never possible before.

Coupled with our new organisational values (set out in the previous section), which are part of our People Strategy, we aim to enhance the services we provide to the public and stakeholders, whilst continuing to be a supportive employer.

We are a large organisation providing a diverse range of public services – but a common thread runs through all that we do. Our three core values: ambitious, collaborative and service focused are central to the way we work. They influence the way we plan, make decisions, how we behave towards one another and continually challenge ourselves to achieve our vision.

The importance of working impartially and ethically should not be understated. The concepts of equality, diversity and fairness are hard-wired in to each of these values and the work that we are completing to review our pay systems.

Examples of our key service delivery developments (across the full organisation) in this reporting period to better promote equality of opportunity and good relations are as follows; we have identified relevant outcomes and improvements achieved and where possible linked to the ICO equality scheme.

Summary of Action Taken Business and E&D Impact Groups most benefitting

from the action

The ICO operates the

‘Disability Confident’

standard of guaranteed

interviews for disabled job

applicants who meet the

minimum criteria for the job.

Encourages a diversity of

experience in the workforce

and improves accessibility of

job opportunities to disabled

people.

Disabled people

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We have enabled staff who

hold a ‘blue badge’ to be

members of the staff parking

scheme without paying the

standard membership fee.

Blue badge holders are also

prioritised, so they can join

the scheme without being on

the waiting list.

Enables disabled colleagues

to park close to our buildings

and at no cost.

Disabled staff who possess

a blue badge.

We provide a wide range of

adjustments for staff, and

have implemented systems

for anticipating the

requirements of new joiners

to our organisation.

Ensuring that disabled staff

(including new starters), and

those with shorter term

health conditions, are able to

work comfortably and have

the equipment and work

arrangements needed to

work effectively.

Disabled staff and staff with

health conditions.

We have ensured that our

office spaces are accessible

and have adequate facilities

for disabled staff.

Providing equal access to

building facilities and

improving convenience for

all staff.

Disabled staff and those with

difficulties accessing

facilities elsewhere in the

building.

We provide learning

materials in a variety of

formats to meet the needs of

staff undertaking training.

Ensures that all staff are

able to fully access training

and equally able to benefit

from the desired learning

outcomes.

Staff with varying learning

styles or who have

disabilities such as visual

impairments or dyslexia

We continue to use our Live

Chat online service for our

helpline. This enables

customers to access our

services in a new way, and

is of potential benefit to

hearing impaired customers.

Enables customers to

contact via a wider range of

methods and improves

accessibility of our services.

All customers who have

difficulties with, or prefer not

to have, telephone

interactions.

We make adjustments,

using our Reasonable

Adjustments policy, to the

way we provide services to

customers who are

Improvements to the

services to all customers

and promotion of

accessibility of information

rights.

Disabled people and others

for whom access to our

services may be difficult.

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otherwise unable to access

our services.

We are developing a Well-

being strategy which aims to

support staff to be well at

work.

Improving staff welfare and

awareness of support.

ICO staff, particularly those

with caring responsibilities.

We provide enhanced

maternity, paternity,

adoption and shared

parental leave and pay

provisions.

Supports parents with their

caring responsibilities and

encourages retention of

experienced staff.

Parents and those with child

care responsibilities.

We have delivered a variety

of awareness sessions for

staff, such as deaf/hearing

impairment awareness;

Asperger’s; and autism

awareness.

Improved appreciation of

different disabilities and

greater understanding of

how the ICO can meet the

needs of customers.

Disabled people

We have produced Equality

and Diversity factsheets to

support staff to develop their

knowledge of equality and

diversity issues.

There are four factsheets,

called Doing the duty, ‘What

is a disability?’, ‘Useful

Equality and Diversity

websites’ and ‘Top tips on

how to behave around

people with a disability’ . We

also have produced a

Dyslexia style guide –

‘Communicating to someone

with Dyslexia’

Customers affected by the

conditions covered by the

factsheets.

We held an internal

campaign raising awareness

of language and terms

people use which may be

offensive to those who have

a mental health condition.

Improved awareness and

understanding of the issue.

Promotion of inclusiveness.

People who have mental

health conditions.

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We conducted a well-being

survey of our staff members

to understand what we do

well, and what we could

improve.

Directing the development of

our Well-being strategy and

action plan – helping the

ICO to be a better employer.

ICO staff

We have developed the ‘Be

aware’ campaign to help

people to understand how

organisations may use data

about them to target them

on line.

Increasing public awareness

of this issue, reducing

vulnerabilities.

All members of the

community

We have developed, and are

consulting upon, an Age

Appropriate Design Code to

protect children and young

people by implementing

standards for information

society services eg apps,

websites, games,

programmes and online

community environments.

Enhancing the protection of

young people on line by

implementing safeguards for

their personal information to

be enacted by service

providers.

Children, young people and

their parents.

We have investigated cases

concerning the disclosure of

information relating to

gender reassignment,

ethnicity, sexual orientation

and disability amongst

others.

Our enforcement action

emphasises the importance

of ensuring the security of

such sensitive data.

Providing protection for

people who have very

sensitive personal data held

by organisations. Helping to

improve compliance with the

law.

A range of groups across

society.

We have taken enforcement

action against companies

who have sent millions of

nuisance texts and spam

emails to the public and

have targeted people for

scam cold calling.

Protecting the general

public, particularly those in

the most vulnerable groups,

for example the elderly.

All of the community, but

with particular benefit for the

most vulnerable people.

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We have taken enforcement

action against an

organisation which illegally

shared the data of parents

and their babies which they

obtained for a different

purpose.

Ensuring that the data of

new parents and children is

protected, and is only used

for the purpose for which it

was provided and not for

data brokering.

New parents and children

We have fined a local

authority for inappropriately

sharing information about

people featuring on a ‘gangs

matrix’ in respect of

suspected gang members.

The information shared

featured a high proportion of

people from Black and

Minority Ethnic communities.

Ensuring that organisations

who have access to such

sensitive information treat it

with care. Protecting

people’s data from across

the community, in this

instance particularly people

from Black,

Asian and Minority Ethnic

communities

All of the community.

We have provided guidance

for GPs and their patients

about accessing medical

records.

The guidance will help GP

surgeries comply with the

law and provide improved

access to records for their

patients.

All of the community, with

particular benefit for regular

users of GP services.

We have undertaken a wide

range of speaking

engagements covering the

public, private, charity and

third sectors.

Cascading good information

rights practise across

society.

All of the community.

Issuing a grant to the

London School of

Economics for a project

looking at children’s

information rights and

privacy, particularly with

regard to children’s capacity

to consent and the

production of an accessible

online toolkit for children,

Improving our knowledge

and better more accessible

guidance for children and

those who work with them.

Children and others who

work with them.

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parents and teachers.

A number of additional activities undertaken during the year impacted directly on people;

The ICO endeavours to provide services for the public which are accessible and take account of individual needs. One example of our work is included in this link which sets out our work with regard to nuisance calls https://ico.org.uk/action-weve-taken/nuisance-calls-and-messages/. We also ensure the widest possible access for individual customers through our Reasonable Adjustment Policy.

Our Equality and Diversity Committee continue to ensure that equality underpins all of our work. This has resulted in the development of awareness days and training sessions and the formation of a Gender Recognition Policy. We are also working on the establishment of a Women’s network. In addition the Equality and Diversity ensured the consideration of equality in Accommodation issues, Dress codes and the Change Management programme.

The Equality and Diversity Committee was also the focus for improving the use of appropriate language in the context of disability and mental health.

Training concerning Alzheimer’s disease has been delivered to staff to raise awareness and improve customer services to those affected by the condition.

We have introduced access to the Civil Service Learning e learning portal for staff. This provides access to a range of equality training programmes and staff have been encouraged to explore and undertake the training – for example Disability Awareness, LGBT Awareness and Race and Ethnicity Awareness. We have also used the portal to mandate unconscious bias training for managers going through our recruitment training programme.

We recently worked with the British Board of Film Classification consulted us on draft guidance about its role as the age verification regulator for access to pornography. We provided input on the data protection issues that pornography providers must consider when implementing age verification mechanisms.

In Northern Ireland;

Throughout 2018/19, we provided support to both people and organisations through our

regional helpline and advice service. This ensured people were aware of their rights under the

new data protection regime. Equality categories impacted: All.

We held an event about GDPR and the new data protection regime at Northern Ireland

Council for Voluntary Action (NICVA). NICVA’s membership includes a wide range of equality

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representative groups in Northern Ireland. Equality categories impacted: All.

In May 2018 we presented to staff of Northern Ireland Commissioner for Children and Young

People (NICCY) about GDPR and the implications of the new data protection regime on

children and young people. This included the need to have due regard for children who are

often vulnerable and whose personal data merits particular protection under the GDPR and

those who are child carers. Equality categories impacted: age, those with dependants.

In April 2018, we held an awareness raising session with Members of the Legislative Assembly

(MLA’s) and their staff in Stormont about the introduction of GDPR. This ensured that MLA’s

were aware of the data protection rights of the people that they represent and were

preparing accordingly. In September 2018, we held a post GDPR implementation session with

the same cohort to ensure they were complying with the new data protection requirements.

Equality categories impacted: All equality categories particularly political opinion.

In May 2018 we met with the Northern Ireland Guardian Ad Litem Agency to assist with

queries and provide data protection guidance to those who safeguard the interests of

vulnerable children who are the subject of Court proceedings. Equality categories impacted:

Age

Between June and December 2018, we undertook an extensive piece of engagement in the

form of meetings and workshop with the former Citizen’s Advice Bureaux in NI about data

protection. They represent a wide range of often vulnerable citizens spanning all equality

categories in NI. Equality categories impacted: All.

We held a session with several Advice NI staff on GDPR, Privacy notices and consent. Their

membership includes a wide range of equality representative groups in NI. Equality categories

impacted: All.

We spoke at the Irish Cardiac Society conference about Data Protection Compliance to health

professionals working with vulnerable patients and handling vast amounts of special category

(sensitive) data. Equality categories impacted: All.

We carried out a workshop for Information Governance staff across all the regional colleges in

NI to discuss data protection and the Privacy and Electronic Communication Regulations and

the impact of these on their students who are often pre dominantly young people. Equality

categories impacted: mainly age

We delivered several workshops to the Northern Ireland Civil Service on carrying out Data

Protection Impact Assessments. This ensures that government departments are following

processes that will help them to identify and minimise data protection risks of their work to

individuals. Equality categories impacted: All

In November 2018, we spoke at an Early Years conference about Data Protection and

children’s rights to staff and professional working in this field. They work with children and

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parents alike. Equality categories impacted: Age and those with dependants.

We responded to the consultation on The Historical Institutional Abuse Bill and subsequently

met with the Executive Office. Providing this response and guidance on the protection of these

very vulnerable data subjects and ensuring all risks to their privacy are assessed and mitigated.

Equality categories impacted: all.

We presented to and sat on various meetings of the Local Government Information

Governance group within the local councils. This ensured we distilled messages and guidance

about Data Protection, Freedom of Information, Environmental Information Regulations and

other information rights legislation to staff who represent those who live and work in their

council areas. This spanned all geographical areas of Northern Ireland. Equality categories

impacted: All

We have engaged with the PSNI in areas such as cyber crime to ensure that the ICOs guidance

and innovative thinking in this area is promoted. Equality categories impacted: All but

particularly age.

We have met with and presented to various health bodies and information governance

advisory groups to include Health and Social Care Trusts, the Health and Social Care Board, as

well as the BMA to discuss GDPR and patient data. Equality Categories impacted: all.

A number of other key points highlight the extent to which equality remains a focus for the

Northern Ireland ICO office;

The Head of ICO Regions is a co-chair of the Equality and Diversity committee for the ICO. This

ensures regional representation on equality issues which feeds into the wider work of the ICO.

• As an employer we have continued to support flexible and part time working, and have

supported staff with caring responsibilities.

• We have updated our Staff Code of Conduct which emphasises the requirement to provide

excellent and unbiased services to all members of the public, and treat colleagues with

respect.

• We have produced Equality and Diversity factsheets at the ICO to support staff to develop

their knowledge of equality and diversity issues. There are four factsheets, called Doing the

duty, ‘What is a disability?’, ‘Useful Equality and Diversity websites’ and ‘Top tips on how to

behave around people with a disability’ . We also have produced a Dyslexia style guide –

‘Communicating to someone with Dyslexia’. The Northern Ireland Regional Office contributes

to the promotion of this resource in the region.

• We have held wellbeing awareness weeks, in all of the ICO offices, to include the Northern

Ireland Regional Office and sessions increasing understanding of Mental Health issues. Our

staff training regularly includes Dignity, Diversity and Inclusion training and sessions

concerning autism and Asperger’s with a view to improve the provision of our services

provided to people affected by these conditions.

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• The Northern Ireland Regional Office, like the other offices of the ICO, has participated in and

supported the campaign to raise awareness of mental health by joining in the discussion

around potentially offensive language. This involved displaying posters and promoting the

new online resources and factsheets that were created on mental health awareness.

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3 Has the application of the Equality Scheme commitments resulted in any changes to policy, practice, procedures and/or service delivery areas during the 2018-19 reporting period? (tick one box only)

Yes X No (go to Q.4) Not applicable (go to Q.4)

Please provide any details and examples:

The work of the Equality and Diversity Committee contributed to the ongoing development of our approach to promoting equality across the organisation. Each directorate’s business plan now incorporates E&D Objectives and departments are required to report on activity which has an equality dimension.

User testing of processes for GDPR readiness and online reporting has included the requirement for the reporting tool to meet accessibility standards.

We also published Annual Equality Reports (NI and GB) – published staffing information including Gender Pay Gap Data.

The ICO has signed up for the Disability Confident Standard which will further enhance our ability to attract and retain disabled people into our employment. We also ensure that reasonable adjustments are made for staff including when taking accredited exams (such as the provision of additional time, separate work equipment etc).

3a With regard to the change(s) made to policies, practices or procedures and/or service delivery areas, what difference was made, or will be made, for individuals, i.e. the impact on those according to Section 75 category?

Please provide any details and examples:

By ensuring that business plans have an equality dimension, we will increase focus on the ICO’s aim to ensure that information rights are accessible to all. Additional consideration will be given to ensure that communities, or individuals with specific needs, are not excluded from the development of information rights laws and practices.

Ensuring that our online reporting tool for GDPR is accessible, will enable a greater proportion of people to engage with the ICO. This will allow people who have specific needs of the IT functionality to report concerns and contribute to our aim to have accessible services and reach across the community.

Our adjustments will enable staff to take accredited exams and develop personally, which may have been more challenging had those changes not been made. The work of the Equality and Diversity Committee led to a higher profile for the consideration of mental health issues and appropriate language around mental in our work.

Internally we have reviewed our processes for on-boarding new staff who are disabled or who have requirements for additional equipment or adjustments to our standard working environment or processes. This ensures that we give full consideration to the needs of disabled staff and the broader environment they work in.

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We have also adjusted our car parking policy so that holders of blue badges no longer need to pay to be part of the ICO’s staff parking scheme.

One of the most important areas of work this year has been the development of the Age Appropriate Design Code. A key concept of the GDPR is that children merit special protection. This code will help to achieve that by setting out the standards of age appropriate design which we expect providers of online services and apps to meet when their services are likely to be used by children or when they process children’s personal data. This is a key example of how important and effective data protection by design can be. The code builds on a set of minimum standards to be taken into account, which were provided by Parliament.

3b What aspect of the Equality Scheme prompted or led to the change(s)? (tick all that apply)

As a result of the organisation’s screening of a policy (please give details):

As a result of what was identified through the EQIA and consultation exercise (please give details):

X As a result of analysis from monitoring the impact (please give details):

An assessment of the impact of the implementation of the GDPR, and the need for a high degree of awareness of the requirements of the new laws.

Our Equality and Diversity Committee also acts as a sounding board for issues that have the potential to impact on staff. This led to work aimed at greater understanding of mental health issues and appropriate language used and the review of the Equality and Diversity Committee will provide a vehicle for new areas of focus including women, Gender recognition and trans issues and disability.

As a result of changes to access to information and services (please specify and give details):

X Other (please specify and give details):

We publish Equality Information in line with NI and GB legislation.

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Section 2: Progress on Equality Scheme commitments and action plans/measures

Arrangements for assessing compliance (Model Equality Scheme Chapter 2)

4 Were the Section 75 statutory duties integrated within job descriptions during the 2018-19 reporting period? (tick one box only)

Yes, organisation wide

Yes, some departments/jobs

No, this is not an Equality Scheme commitment

No, this is scheduled for later in the Equality Scheme, or has already been done

X Not applicable

Please provide any details and examples:

The ICO is a UK wide organsiation and staff have to comply with equality legislation and obligations from a number of jurisdictions. It has established an Equality and Diversity Committee that ensures appropriate consideration of equality issues across those jurisdictions with a view to mainsteaming equality throughout the organisation.

Although not a specific commitment, consideration of E&D matters and behaviours in this regard is a core part of our code of conduct which was updated in January 2019. Staff are required to work with integrity, without bias or maladministration and in accordance with the ICO’s policies and procedures. This includes our Discplinary Policy and Dignity and Work Policy which set out examples of unacceptable behaviour.

The concepts of equality and diversity are reflected within the organisation's Values Framework - a key area of which is 'fairness', and all staff are required to undertake Dignity, Diversity and Inclusion training when they start working with the ICO.

This is fully supported by our People Strategy which has a number of goals and actions that support staff anf promote equality. These include:

People Strategy Goal 1: Inspire continuous improvement through common values and a high performance culture.

Develop leadership capability, equipping and empowering our managers to lead effective teams

Action: Building on our Management Forum, develop a leadership profession at the ICO based on the development of skills and competencies which light a clear career path from first line manager through to executive leadership.

Challenge, support and develop people so they can deliver first class services

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Action: Review our personal development practices and processes to ensure they facilitate frequent ‘check ins’ between people and their managers and provide ongoing support and challenge.

Action: Complete the implementation of a coaching and mentoring programme to enable our people to be resourceful when exploring ways to develop and improve and be the best they can be.

People Strategy Goal 2: To be the best employer we can be, attracting and retaining the very best talent.

Recruit the best possible people

Action: We will routinely profile the diversity of our workforce and actively ensure our policies, working practices and environment are conducive to attracting and retaining staff with a diverse range of skills, backgrounds and working styles and preferences. This includes identifying potential or actual inequalities in our practices and taking swift action to remove them.

Provide opportunities for professional and personal development

Action: We will implement an on-going review of our people policies to ensure that they provide a framework for working which is relevant, suited to the needs of the business and consistent with our values.

Our total reward package, benefits and ways of working will enable us to attract and retain the best people

Action: Establish varied and impactful ways for all ICO staff to share their views and be consulted on matters of importance – including a range of staff and management forums, regular engagement surveys and constructive industrial relations with our recognised trade unions.

Grow a culture where caring and supporting others is valued and the ICO is a good corporate citizen

Action: In addition to implementing a wellbeing policy and associated action plan, we will develop a social responsibility plan to promote how we can collectively and individually benefit the community and wider society as a whole.

Provide inspiring, effective, safe and accessible workplaces and flexible approaches to work

Action: Through the work of the Accommodation Project, ensure that our accommodation remains adequate and fit for purpose in line with the standards expected of a modern regulator and employer of choice.

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5 Were the Section 75 statutory duties integrated within performance plans during the 2018-19 reporting period? (tick one box only)

X Yes, organisation wide

Yes, some departments/jobs

No, this is not an Equality Scheme commitment

No, this is scheduled for later in the Equality Scheme, or has already been done

Not applicable

Please provide any details and examples:

Each directorate’s business plan now incorporates E&D Objectives and departments are required to report on activity which has an equality dimension.

In the 2018-19 reporting period were objectives/ targets/ performance measures relating to the Section 75 statutory duties integrated into corporate plans, strategic planning and/or operational business plans? (tick all that apply)

X Yes, through the work to prepare or develop the new corporate plan

X Yes, through organisation wide annual business planning

Yes, in some departments/jobs

No, these are already mainstreamed through the organisation’s ongoing corporate plan

No, the organisation’s planning cycle does not coincide with this 2018-19 report

Not applicable

Please provide any details and examples:

The impact of this work in Northern Ireland and in other jurisdictions has led to;

Development of four statutory codes of practice which we are required to produce under the DPA 2018. These codes will focus on age appropriate design, data sharing, direct marketing, and data protection and journalism.

Broadening our communications channels to raise greater awareness of information rights across the UK;

Raising awareness of information rights in across GB and including Northern Ireland;

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Working with organisations, including the British Board of Film Classification and those concerned with children’s safety on the internet, to maximise the impact of guidance on how individuals can protect themselves against information rights risks;

To better understand public concerns about information rights by working with civil society and other groups, which are representative of those affected by information rights issues, and by using our own research.

Extending the ICO’s reach into all parts of the country and sections of society to achieve equality of access to information rights and our services.

Embedding diversity and our values so that they are an everyday part of how we work and of our decision making.

The development of our new corporate plan has set out high level strategic goals, of which the enhancement of public trust in how their information is handled, and the development of information rights practices by organisations are core. The delivery of Section75 duties (and their equivalent in the Equality Act) , and the fair use of information, are integral to these goals.

Equality action plans/measures

7 Within the 2018-19 reporting period, please indicate the number of:

Actions completed:

N/a Actions ongoing: N/A Actions to commence:

N/A

Please provide any details and examples (in addition to question 2):

In Section 1 and 2 of this document we have cited several examples of our plans and actions which promote equality issues within our People Strategy and which impact on improving equality and accessibility of our services and information rights for the public. These are embedded within our corporate plans and business plans. This is supported by a directive to all Departments to include equality and diversity objectives and actions.

In addition we have sought to provide opportunities to engage disabled people in public life through our recruitment campaigns for senior management positions and positions on the Management Board of the ICO which encouraged applications from all members of the community.

8 Please give details of changes or amendments made to the equality action plan/measures during the 2018-19 reporting period (points not identified in an appended plan):

Not applicable.

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9 In reviewing progress on the equality action plan/action measures during the 2018-19 reporting period, the following have been identified: (tick all that apply)

X Continuing action(s), to progress the next stage addressing the known inequality

Action(s) to address the known inequality in a different way

Action(s) to address newly identified inequalities/recently prioritised inequalities

Measures to address a prioritised inequality have been completed

The ICO approach involves a continued assessment of equality issues through the Senior Leadership Team and the Equality and Diversity Committee. Examples of how these are addressed are set out in Section 1 and in Section 2.

Arrangements for consulting (Model Equality Scheme Chapter 3)

10 Following the initial notification of consultations, a targeted approach was taken – and consultation with those for whom the issue was of particular relevance: (tick one box only)

All the time X Sometimes Never

11 Please provide any details and examples of good practice in consultation during the 2018-19 reporting period, on matters relevant (e.g. the development of a policy that has been screened in) to the need to promote equality of opportunity and/or the desirability of promoting good relations:

The Data Protection Act places obligations on the Information Commissioner to consult on guidance and codes of practice where appropriate. We publicise our consultations through our website, newsletters and by targeting particular groups when that is relevant.

Our Consultation Policy sets out the timeframes used for consultations and stipulates that documentation is written in plain English and in a format compatible with the website’s Browsealoud facility. Consultation documentation can also be made available in braille or audio format.

Our policy states that if face to face consultation sessions take place, the needs of participants will be fully considered and venues chosen which are fully accessible.

We have consulted on the concept of ‘consent’ under GDPR, which incorporates issues around capacity and ability to provide informed consent. We have also taken forward consultation concerning the Privacy Notice Code of Practice.

As part of the lead up to the implementation of GDPR we have held ‘listening post’ events to provide organisations with the opportunity to influence the interpretation and UK implementation of the new regulations.

During 2018/19 we consulted on a number of issues:

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As part of the new People Strategy, in January 2019 we consulted with all staff on our new wellbeing policy. Over 380 staff responded to this consultation. The new policy will be launched during 2019-20.

We also began our consultation on the Age Appropriate Design Code with an initial call for views on this very important and sensitive subject. Initial consultation was conducted on the Data Sharing Code, Direct Marketing Code and Data Protection and Journalism Code.

12 In the 2018-19 reporting period, given the consultation methods offered, which consultation methods were most frequently used by consultees: (tick all that apply)

X Face to face meetings

X Focus groups

X Written documents with the opportunity to comment in writing

Questionnaires

Information/notification by email with an opportunity to opt in/out of the consultation

Internet discussions

Telephone consultations

Other (please specify):

Please provide any details or examples of the uptake of these methods of consultation in relation to the consultees’ membership of particular Section 75 categories:

13 Were any awareness-raising activities for consultees undertaken, on the commitments in the Equality Scheme, during the 2018-19 reporting period? (tick one box only)

Yes X No Not applicable

Please provide any details and examples:

14 Was the consultation list reviewed during the 2018-19 reporting period? (tick one box only)

Yes X No Not applicable – no commitment to review

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Arrangements for assessing and consulting on the likely impact of policies (Model Equality Scheme Chapter 4)

15

Please provide the number of policies screened during the year (as recorded in screening reports):

3

16 Please provide the number of assessments that were consulted upon during 2018-19:

0 Policy consultations conducted with screening assessment presented.

0 Policy consultations conducted with an equality impact assessment (EQIA) presented.

0 Consultations for an EQIA alone.

17 Please provide details of the main consultations conducted on an assessment (as described above) or other matters relevant to the Section 75 duties:

N/A

18 Were any screening decisions (or equivalent initial assessments of relevance) reviewed following concerns raised by consultees? (tick one box only)

Yes No concerns were raised

No X Not applicable

Please provide any details and examples:

Arrangements for publishing the results of assessments (Model Equality Scheme Chapter 4)

19 Following decisions on a policy, were the results of any EQIAs published during the 2018-19 reporting period? (tick one box only)

Yes No X Not applicable

Please provide any details and examples:

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Arrangements for monitoring and publishing the results of monitoring (Model Equality Scheme Chapter 4)

20 From the Equality Scheme monitoring arrangements, was there an audit of existing information systems during the 2018-19 reporting period? (tick one box only)

Yes No, already taken place

No, scheduled to take place at a later date

X Not applicable

Please provide any details:

21 In analysing monitoring information gathered, was any action taken to change/review any policies? (tick one box only)

Yes No X Not applicable

Please provide any details and examples:

22 Please provide any details or examples of where the monitoring of policies, during the 2018-19 reporting period, has shown changes to differential/adverse impacts previously assessed:

See response to Q23

23 Please provide any details or examples of monitoring that has contributed to the availability of equality and good relations information/data for service delivery planning or policy development:

The ICO has a range of mechanisms and methods for collecting information that can inform policy development and assess performance which can support our efforts in relation to advancing equality of opportunity (for example our Annual Track, ‘Mystery Shopper’ surveys, and the Citizen’s Reference Panel). Collecting information to help understand inequalities and the needs of staff and customers is central to the role of the Equality and Diversity Committee in informing Corporate Policy. Our annual track in 2018 was also published around August/September: https://ico.org.uk/media/about-the-ico/documents/2259732/annual-track-2018.pdf

We are keen to identify ways to enhance the information we gain from these in relation to the particular experiences of people with protected characteristics in order to ensure a more inclusive and responsive service, for example we retain a log of customers for whom

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adjusted services are required to support their needs, and we have mapped the adjustments made to support staff.

We continue to monitor recruitment processes to ensure that they are conducted fairly and encourage applications from across the whole community.

Staff Training (Model Equality Scheme Chapter 5)

24 Please report on the activities from the training plan/programme (section 5.4 of the Model Equality Scheme) undertaken during 2018-19, and the extent to which they met the training objectives in the Equality Scheme.

ICO Staff receive training regarding their equality obligations as part of their induction. This is supported by a range of courses including ‘Dignity, Diversity and Inclusion’ which is designed to ensure that staff are aware of their rights and obligations in respect of equality matters and the equality principles of the work of the ICO. A total of 222 staff were trained in 2018/19.

We run a course that builds awareness of Mental Health issues and Autism Spectrum disorders. This course is designed to gain an understanding of how these often complex conditions can result in levels of distress and lead to breakdowns in communication resulting in a poor customer service experience. In 2018/2019 we trained 86 staff.

In the past year 125 staff at Management level completed a course on Unconscious Bias. Senior staff also attended public seminars including “ Black and Minority Ethnic people into Leadership” and “Proud to Provide conference” which was focused on the delivery of public services to the LGBT+ community.

Internal sessions and briefing were also held for staff on issues including wellbeing, stress awareness and pension awareness.

Managers receive training on employment law issues which include an equality dimension. In addition we recently launched an on-line training resource for managers called ‘Planning for Equality’ which is designed to allow decision makers aware of how equality issues can be addressed by design, rather than being an ‘add on’ at the end of the planning process.

We have continued our recruitment training for managers, which addresses issues such as employment law, fairness and unconscious bias. This helps to ensure that our processes are fair and focussed on selecting candidates based on their skills, knowledge and abilities.

We also operate a course for new Managers which is centred on orientation but includes understanding the equality objectives and ethos of the ICO.

The ICO also has access to the Civil Service e-learning portal which includes awareness training relating to a variety of protected characteristics. All staff are required to establish a Civil Service Learning e-learning account.

Staff are also supported to attend a wide range of external training courses and events, many of which have an equality dimension such as Human Rights training or targeted sessions run by representative groups.

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25 Please provide any examples of relevant training shown to have worked well, in that participants have achieved the necessary skills and knowledge to achieve the stated objectives:

All of our training has been viewed as adding value to the organisation and the skills and experience of the individuals who have undertaken it. As in previous years, our training sessions on Mental Health issues have been particularly well received.

Public Access to Information and Services (Model Equality Scheme Chapter 6)

26 Please list any examples of where monitoring during 2018-19, across all functions, has resulted in action and improvement in relation to access to information and services:

Our communications need to be accessible to as wide a range of people as possible.

We seek to comply with the principles of inclusiveness that incorporate the provisions of Section 75, the Equality Act, and the Welsh language requirements.

The ICO website meets AAA accessibility standards wherever possible (the government requires AA status). This means, for example, that text size can be altered and a browsealoud facility is available. This functionality has been improved in the last twelve months.

All publications are produced to accessibility standards and the corporate “Style Guide” also incorporates this good practice. For example all ICO publications:

use sans serif fonts for core text;

use a font size of 12 point minimum and 14 points for important information;

maximise white space

use a dark out of white colour scheme

use good quality matt paper to reduce glare and the text showing through from the other side.

The ICO also trains staff to write in plain English and has produced a “Style Guide”. The ICO:

limits sentences to between 15 – 20 words;

avoids dense block text paragraphs;

uses line spacing between paragraph breaks;

keeps lines left justified with a ragged right edge;

uses bullets or numbers rather than continuous prose;

uses fact boxes to make main point clear;

uses images where possible to support text; and

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seeks accreditation by the ‘Plain Language Commission’ for key leaflets and guidance.

We do not have the budget to undertake translation of all publications as a matter of course, but we will respond to individual requests in line with our Translations Policy, which can be found on our website. We have a duty to manage our funds effectively and make sure that our resources are allocated in a way that maximises impact in a proportionate manner. Our operational procedures establish approaches both for handling customers with particular needs and making ‘reasonable adjustments’ as defined within equality legislation.

In relation to learning and development, flexible options are built in covering timing of events, location, format of materials and method of delivery. The ICO also ensures that work related events, and any refreshments served there, are inclusive as possible taking particular account of religion or belief.

In addition to these long standing arrangements, the ICO has ‘live chat’ services which enable members of the public to interact with the organisation online. This has promoted accessibility for those who may feel anxious using the telephone helpline service, or perhaps have hearing impairments which could be a barrier to using the service.

We retain an adjustment log so that we are aware of the circumstances when customers have required an alteration to the services we provide in order to meet their needs. We have an allocated officer who oversees the log and makes sure that we adhere to the adjustments agreed with the customer. This is an on-going resource which is continually updated.

Our Customer Services training has contributed to the outstanding performance assessment of our Customer Helpline. Our on-line ’live chat’ service from the helpline provides members of the public with the opportunity to communicate with the helpline through real time written communication. This is another means of improving accessibility of our services for individuals who have difficulties speaking or hearing.

Complaints (Model Equality Scheme Chapter 8)

27 How many complaints in relation to the Equality Scheme have been received during 2018-19?

Insert number here: 0

Please provide any details of each complaint raised and outcome:

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Section 3: Looking Forward

28 Please indicate when the Equality Scheme is due for review:

Our Equality scheme was submitted for approval in 2014 and is therefore scheduled for a five year review during 2019.

29 Are there areas of the Equality Scheme arrangements (screening/consultation/training) your organisation anticipates will be focused upon in the next reporting period? (please provide details)

We are seeking to transform our governance of Equality and Diversity so that we can be inclusive of more people and more proactive in our work, which will reflect the extent to which the ICO has grown in the last two to three years. Our current Equality and Diversity Committee is made up of representatives from across the ICO. Members bring with them a range of experiences, as well as their insight into operational matters. They help to advise upon equality issues, and raise awareness around the organisation.

The Committee includes two members of our Senior Leadership Team, and so has direct links to the most senior levels of management in the organisation.

However, we feel we can improve on this by re-structuring how the group works. During 2019 we will form network groups for staff who have a variety of protected characteristics. Those groups will also welcome members who are not part of the protected group, but are supportive of their interests. For example, we anticipate forming a women’s group; a disabled staff group; a Rainbow Group for LGBT+ colleagues; and any other groups for which there may be a reasonable demand.

Nominated chairs of each of these groups will attend the new Equality and Diversity Forum. The Forum will receive feedback from the groups, seek their input and views about the development of the ICO and feed this into the Senior Leadership team.

We feel that this will enable more people to contribute on issues which they feel really impact upon them, and allow us to have a more inclusive and influential workforce.

30 In relation to the advice and services that the Commission offers, what equality and good relations priorities are anticipated over the next (2018-19) reporting period? (please tick any that apply)

Employment

Goods, facilities and services

Legislative changes

X Organisational changes/ new functions

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Nothing specific, more of the same

Other (please state):

We are seeking to transform our governance of Equality and Diversity so that we can be

inclusive of more people and more proactive in our work, which will reflect the extent to which

the ICO has grown in the last two to three years

Our current Equality and Diversity Committee is made up of representatives from across the

ICO. Members bring with them a range of experiences, as well as their insight into operational

matters. They help to advise upon equality issues, and raise awareness around the

organisation.

The Committee includes two members of our Senior Leadership Team, and so has direct links

to the most senior levels of management in the organisation.

However, we feel we can improve on this by re-structuring how the group works. During 2019

we will form network groups for staff who have a variety of protected characteristics. Those

groups will also welcome members who are not part of the protected group, but are supportive

of their interests. For example, we anticipate forming a women’s group; a disabled staff group;

a Rainbow Group for LGBT+ colleagues; and any other groups for which there may be a

reasonable demand.

Nominated chairs of each of these groups will attend the new Equality and Diversity Forum.

The Forum will receive feedback from the groups, seek their input and views about the

development of the ICO and feed this into the Senior Leadership team.

We feel that this will enable more people to contribute on issues which they feel really impact

upon them, and allow us to have a more inclusive and influential workforce.

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PART B - Section 49A of the Disability Discrimination Act 1995 (as amended) and Disability Action Plans

1. Number of action measures for this reporting period that have been:

N/a

N/a

N/a

Fully achieved Partially achieved Not achieved

2. Please outline below details on all actions that have been fully achieved in the reporting period.

2 (a) Please highlight what public life measures have been achieved to encourage disabled people to participate in public life at National,

Regional and Local levels:

Level Public Life Action Measures Outputsi Outcomes / Impactii

Nationaliii

We ensure that anyone can apply to be a member of the ICO Management Board, and make a statement within our advertisements that we welcome applications from members of all communities

Disabled people can apply for these positions, and have done so in recent recruitments.

Ensuring disabled people have the right to apply for these positions and have adjustments made to the process if necessary. This therefore increases access opportunites within public life as well as promote good practice with others. It ensures that disabled have an influential voice at the highest level.

Regionaliv Across the ICO, we ensure a policy for disabled staff to have reasonable adjustments which enables them to

This reasonable adjustment policy ensures that all staff have an opportunity to

All staff can participate in any internal groups within the ICO, such as the ICO green group which aims

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apply for work, or stay in work if they become disabled.

This is enhanced by an “on-boarding” approach that works individually with disabled staff to ensure the specific needs are met as well as addressing the wider workplace environment.

undertake any internal public life opportunities.

Dosabled staff are better integrated to their work environments.

to raise awareness of environmental issues across the organisation. Disabled staff represent the ICO to external stakeholders and customers.

More effective disabled staff .

Localv

Overall ICO recruitment takes account of any applicants with disabilities. We apply the ''Two Ticks'/Disabiity Confident standard which guarantees a job interview for disabled candidates who meet the minimum specification for the job for which they have applied

Ensures access opportunities for all staff who apply to the ICO, including any people with disabilities.

Fair recruitment practice to ensure people with disabilities can apply for ICO positions.

2(b) What training action measures were achieved in this reporting period?

Training Action Measures Outputs Outcome / Impact

1

Training on diversity, diversity and inclusion continues to be delivered to all staff, including new starters.

Staff are trained to be aware of the legislation and also be mindful of each other's dignity and the value of diversity to the organisation.

Better service for our staff who are disabled and improved service delivery for disabled people. A more aware and understanding workforce.

2 Issues relating to equality and diversity are referred to in our corporate induction and is being

Staff are trained to be aware of the legislation and also be mindful of each other and be alert to the needs of

Better service for our staff who are disabled and improved service delivery for disabled people.

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expanded to increase impact. These training courses cover all equality strands, which include disability related matters.

customers who may be disabled.

3

The corporate induction includes reference to the Public Sector Equality Duty and Disability Discrimination Act.

Staff are trained to be aware of the legislation and also be mindful of each other.

Better service for our staff who are disabled and improved service delivery for disabled people.

4

Enhanced training for specific roles includes mental health awareness training that incorporates Autism and Aspergers training.

Staff are trained to be aware of the legislation and the potential needs of service users.

Better service for our staff who are disabled and improved service delivery for disabled people.

5

Recruitment training includes reference to reasonable adjustments for disabled job applicants.

Recruiting managers are aware of their legal and policy obligations, and understand the business benefits of diversity and applying a fair approach.

A recruitment process which provides disabled applicants fair to access opportunities, and which encourages applications from people who are disabled.

6

The ICO continues to make reasonable adjustments to training and development opportunities for staff who are disabled. This will help to encourage and retain participation in public life by disabled people.

Training venues are selected to ensure that they are accessible for disabled delegates. This includes sending training materials in advance or in different formats for disabled delegates for whom the standard format is not accessible.

Disabled staff have access to the same standard of training that non-disabled staff have, and therefore have equality of access to increased skills and knowledge.

7 We have provided training to staff using a ‘live chat’ service to

The live chat service is operational and staff are trained to provide services.

Live chat provides an alternative method for accessing our services which may be beneficial to disabled people, for example people who are

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access our Customer Services. hearing impaired or have other difficulties using the telephone.

2(c) What Positive attitudes action measures in the area of Communications were achieved in this reporting period?

Communications Action

Measures Outputs Outcome / Impact

8

Delivered training to enhance service to customers of the ICO who have Mental Health and/or Autism and have been identified based on analysis of caller interactions.

Staff are trained to be aware of the legislation and also be mindful of each other.

Better service for our staff who are disabled and improved service delivery for disabled people

9

The E&D committee has identified the opportunity to increase awareness and expertise internally around particular disability issues that affect staff and customers. The ICO also held a Mental Health Awareness Week.

ICO operates a policy whereby customers are supported in receiving services.

Awareness weeks have been carried out in the ICO on equality and diversity issues and blogs been also been completed.

Better service for our staff who are disabled and improved service delivery for disabled people. Increased understanding of some of the issues faced by other protected groups.

10 Departments have been required to complete returns to record the activity they have

We are able to communicate to staff throughout the organisation the nature of the work we do which helps to

Improved awareness of activity in the organisation. Improved communication of this has helped to build links between different

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undertaken which impact on improving equality, diversity and accessibility to information rights and our services

support various groups, including those which support or represent protected groups.

strands of activity and achieve better outputs.

2 (d) What action measures were achieved to ‘encourage others’ to promote the two duties:

Encourage others Action

Measures

Outputs Outcome / Impact

11 As part of the ICO procurement policy, we have taken decisions that have ensured that contractors are not awarded work if there is not an effective equality and diversity plan in place

Organisations who do not take account of appropriate equality measures are not awarded contracts.

Organisations improve and update their practice as a result.

12 We have encouraged other organisations to provide the information to customers in an accessible format and reminded them of their equality obligations.

The public bodies have provided information in an appropriate format.

Better customer service for affected members of the public and increased awareness of equality obligations amongst other organisations.

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2 (e) Please outline any additional action measures that were fully achieved other than those listed in the tables above:

Action Measures fully implemented (other

than Training and specific public life

measures)

Outputs Outcomes / Impact

13 We have continued to complete advisory visits and worked closely with organisations such as the Alzheimer’s Society.

Organisations will more readily provide information to people acting on behalf of people with dementia to help them manage their affairs.

Know about’ sessions run in the ICO have helped educate the ICO staff on how on how better to deal with people with dementia and those acting on their behalf

3. Please outline what action measures have been partly achieved as follows:

Action Measures partly achieved Milestonesvi / Outputs Outcomes/Impacts Reasons not fully achieved

1 The ICO will ensure that equality matters, including those related to disability, are integrated into the business planning process.

Aims completed and working in practice across the organisation

Equality matters are integrated into the business planning process

Progression made on previous years, but not fully integrated to the desired extent.

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4. Please outline what action measures have not been achieved and the reasons why.

n/a

5. What monitoring tools have been put in place to evaluate the degree to which actions have been effective / develop new opportunities for

action?

(a) Qualitative

Work has been completed with disabled staff to ensure reasonable adjustments and appropriate mechanisms are in place and obtain their

views of working at the ICO. This collaboration has enabled us to gather ideas for how we can improve aspects of how we work and our work

environment.

Our helpline services have a reasonable adjustment register and staff who have been designated with responsibility for supporting customers

who have particular needs eg helping members of the public to make Subject Access Requests to organisations if they have difficulty in doing

so.

(b) Quantitative

We report quarterly to our management board. This includes information about the proportion of staff who regard themselves as being

disabled. Our staff survey has been used as a method of gathering demographics about staff which are not systematically gathered using our

HR systems.

If yes please outline below:

Revised/Additional Action Measures Performance Indicator Timescale

1 None

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7. Do you intend to make any further revisions to your plan in light of your organisation’s annual review of the plan? If so, please outline

proposed changes?

Yes, a revised Disability Action Plan is under development.

i Outputs – defined as act of producing, amount of something produced over a period, processes undertaken to implement the action measure e.g. Undertook 10 training sessions with 100 people at customer service level. ii Outcome / Impact – what specifically and tangibly has changed in making progress towards the duties? What impact can directly be attributed to taking this action?

Indicate the results of undertaking this action e.g. Evaluation indicating a tangible shift in attitudes before and after training. iii National : Situations where people can influence policy at a high impact level e.g. Public Appointments

iv Regional: Situations where people can influence policy decision making at a middle impact level

v Local : Situations where people can influence policy decision making at lower impact level e.g. one off consultations, local fora.

vi Milestones – Please outline what part progress has been made towards the particular measures; even if full output or outcomes/ impact have not been achieved.