Transformation Programme   
Equality Impact Assessment   
January 2008  
(Updated October 2009 to take into account any possible inequalities stemming from the Capability Review action plan or latest phase of the Corporate Services improvement programme) 

Our aim is to improve the quality of life for all      through cultural and sporting activities, support the pursuit of excellence, and champion the tourism, creative and leisure industries.

Contents
Transormation Programme EIA	4
Purpose	4
Background	4
Methodology	5
Impact on Staff	5
Potential Adverse Impact	5
Staff Survey	7
Possible Opportunities	8
Actions Going Forward	9
Review	10
Appendix A: Flexible Organisation	11
Appendix B: Evidence Gathering Workshops	12

Transformation Programme EIA
This is an equality impact assessment (EIA) of proposals to transform the ways of working at the Department for Culture, Media and Sport (DCMS).
Purpose

The EIA assesses the department’s transformation programme for its impact on age, race, disability, religion or belief, gender and sexual orientation.  
The transformation programme will deliver the structure and tools to transform DCMS through a series of connected projects, engaging key stakeholders in order to refocus and re-energise staff and raise DCMS’ profile so that it can enhance the impact of what it delivers to its customers.
This assessment is intended to help the change team consider the potential impact of transformation on individual members of staff and diversity in DCMS; to prepare plans to support staff through the changes and to ensure that the plans do not discriminate against staff in the groups outlined above.
Background

The department’s Capability Review report put forward five recommendations that would make the department more effective, and in order to deliver on those recommendations, the Board agreed to a transformation programme for the department. Work was carried out by seven task forces over the summer of 2007 and this culminated in the all staff conference on 18 October.  At the conference, the Board set out the new overall structure of the department, with further details still to be decided (see Annex A). 
All public authorities have a statutory duty to carry out EIAs on functions, policies and practices to assess their potential impact on race, disability or gender equality. Although not a legal requirement, this assessment also considered the other three legally protected “strands”: religion and belief, age and sexual orientation. 
DCMS is therefore required to carry out an EIA on the transformation programme proposals. If the proposals could have an adverse impact on particular groups then, wherever reasonable and practicable, they should be modified to remove or reduce the impact. If there are no other ways of achieving the aims of the particular business proposal, then actions should be taken to mitigate any adverse impacts, wherever reasonable and practicable.

Update -November 2008
The initial restructure of the department took place in April 2008 and set up the new Partnership & Programmes teams- programmes team, three sector teams and External Relations team, PERU. Alongside these new teams new business processes were introduced which all staff were made aware of. A number of other new ways for working were introduced for example developing sector strategies and Whitehall strategies to improve DCMS’s influence on our sectors, NDPBs and across Government. Matrix management was also introduced in the programmes team.
Following the Deloitte report reviewing Corporate Services the Transformation Programme steering board decided that this area of the department also needed to be restructured to ensure it was able to support the already transformed department in the way it needed. This work was started in July 08 and is due for completion in March 09. It will involve developing a new structure for the CS areas with new role profiles which will be followed by a staff allocation exercise. Alongside this work, the CS areas will be identifying their key deliverables and examining how they can work better with the rest of the department to deliver these.

Update October 2009
The restructure of the Corporate Services teams was completed in March 2009. Following this restructure work is now ongoing to improve the ways of working within the teams to ensure that the vision for Corporate Services is fulfilled. This includes developing a Partnership Agreement, Programme Office and introducing new IT solutions e.g. HR Oracle.
 The Capability re-review team reassessed the department in March 2009 and an action plan was put in place to address the issues highlighted. This action plan consists of 16 separate projects, the majority of which will have delivered by September 2009. The Capability re-review team will be revisiting the department in autumn 2009 to assess progress. One of these projects was tackling performance on PQs, correspondence and briefing which is involving a restructure of PERU. This is not being u undertaken by the Change Team and we would expect the PERU project team to complete and EIA for this project.
Methodology

We have gathered evidence directly from some of the department’s staff for their views on how the programme might affect specific groups of staff.  Discussions have been held with representatives of three staff networks (diversity, black and minority ethnic (BME) and flexible workers) about issues that could lead to different outcomes for staff in the various diversity groups (see Annex B). Discussions have also been held with the Trade Unions.
It is important to note that the issues raised are comments from members of staff present at a workshop and not necessarily the views of all staff within the specific group. Furthermore, some of the issues raised by specific groups below could equally apply to other members of staff.
We have also collected data from the 2007 staff survey and subsequent pulse survey; the latter being held more frequently with a smaller sample of staff to chart staff views on various issues related to the transformation programme. Furthermore, some questions were raised by members of staff at the divisional workshops that were arranged with every division in the department by the change team.
For background information, Annex C shows the numbers of staff in the various groups at 30 September 07 within DCMS.
Update- November 2008
Our evidence for the Corporate Services change programme has been gathered from two meetings with the diversity network – one in September and one in November. We have also consulted with all corporate services staff on a draft structure and role profiles for their area. These consultation documents were also shared with the Trade Unions, the new Directors Group and the Diversity Network. We also offered to meet the Trade Unions but this request was declined.
In addition to this we have also continued to collect and monitor data from our pulse survey which we have run four times since the beginning of the Transformation Programme.

Update – October 2009
Our evidence for this phase of the Change Programme has been collected from our pulse surveys and from a number of focus groups held with staff – 2 in July and 2 more planned for November 09.
Impact on Staff

We invited views of staff on two main issues: whether the transformation programme to was likely to have an adverse impact on particular groups of staff and how any such risks could be addressed; and the potential for the programme to promote equality of opportunity for staff.
Update- November 2008
Again we invited the Diversity network to consider whether the proposals for the review of corporate services were likely to have an adverse impact on particular groups of staff and how any risks could be addressed. The consultation documents asked specifically for any comments on the new structure and role profiles.

Potential Adverse Impact

Various issues were expressed by staff as to how the programme might have an adverse impact on specific groups of people. The following points were made:

Generic Issues
A generic concern was the change itself – moving people and teams into new structures can unsettle staff and cause stress. Individuals who had been doing a job for a long time, might find this challenging. lt was considered important that support should be made available for those who need advice or are concerned about the impact of the transformation on their jobs, either through or outside of the line management chain.

Disability
Although no firm plans to hot-desk were in place, any such arrangements would have to be thought through carefully to avoid impacting negatively on staff with a disability or with specific workstation adjustment needs.  The DCMS Trade Union side have expressed major concerns that hot-desking would not only be discriminatory to staff with a disability or with specific workstation adjustment needs, but to staff with caring responsibilities and lower grade staff generally.

Race
As Annex C shows, the department has a higher concentration of BME staff in the lower grades (Grade C and D). Staff are concerned that these members of staff will not see an improvement in the quality of their work and will actually continue to do the chores regarded as ‘boring’. They want to be assured that there will be fluidity between the four different structures of the new organisational design.
BME staff were concerned that it was already difficult to be considered for a new high-profile post when these are allocated as ‘managed moves’.  If ‘managed moves’ continue to be a part of the postings policy, BME staff are worried that where historically they do not have the same access to senior management as others (for example the fast stream) they will be excluded from career development opportunities once again. What they would like is for the BME staff members to have access to senior managers so that they can learn from experience, ask for advice and let senior managers know about their own work experiences. They suggested that managed moves should be monitored by HR to guard against any indirect discrimination.

Gender
As Annex C shows, the department has a higher concentration of female staff compared to male staff in the lower grades (Grade C and D). Staff are concerned that these members of staff will not see an improvement in the quality of their work and will actually continue to do the chores regarded as ‘boring’. They want to be assured that there will be fluidity between the four different structures of the new organisational design.
All DCMS staff can access a range of flexible working patterns and these opportunities are taken up by men and women for a number of reasons, including, but not exclusively related to, domestic responsibilities. No specific gender issues were raised in our discussions.  However, concerns were raised by staff around flexible working patterns and how the restructuring of the department could impact on those who work flexibly.  The restructuring might bring about an expectation that all flexible workers should work only in the project pool. Particular attention would be needed to ensure that there was no abdication of responsibility for performance management, including bonuses, where workers worked for more than one manager in a matrix arrangement. There was also a potential for downward grade drift with instances of workers being fitted into jobs which did not optimise their competence.  
Staff also felt uneasy about what wider opportunities would be available for flexible workers – would they be able to apply for high profile posts or would they only go to those working full time? There were also some concerns around the provision of training for flexible workers and whether they would have the same access to the necessary training (for example, on project management).

Age
It was felt that staff of all ages would need to be supported through the changes but particular attention should be paid to ensure that older staff are not adversely affected, for example, because of management preconceptions or lack of management support.

Religion or belief
Staff at the workshops did not feel that the transformation programme would directly or indirectly have a negative affect on religious groups.

Sexual Orientation
As outlined in the generic issues above, support was necessary for all staff through the change process; this might be particularly important for any LGBT staff with concerns about moving from one team to another. Continued appropriate diversity training would help all members of staff to deal with varied circumstances. Its important to that this potential impact is taken into account with all moves of staff to new posts – in particular this will be feed to the accommodation project team so the impact can be managed in the move to hot desking.
Update – November 2008
There were a number of concerns that were raised by the Diversity network; many of these are about the change programme in general. These were 
•	need to think more about how we engage people (emotionally) with change, both inside and outside Corporate Services; and also about providing more support for staff through the transition;
•	communication and tactful handling of the redeployment process is very important; 
•	concern that the diversity might go down the priority list as there are fewer CS staff facing more work; 
•	the staff allocation/recruitment decisions will need to be monitored to check the outcome has not lead to adverse impacts on any minority groups;
•	need to ensure that the work-life balance does not suffer and staff are still able to work flexibly.

The Trade Unions have also expressed concern with proposed new structure of the corporate services areas. In particular they are concerned that there has not been enough consultation prior to the introduction of a new structure. They are also concerned that the staff allocation process may lead to compulsory redundancies and may have an adverse impact on staff on loan, and that headcount reductions and the staff allocation process will put even greater pressures on staff in corporate services.

Update – October 2009
There have been no equality concerns raised with the latest phase of the corporate services review programme or the action plan projects. A number of concerns have been raised during the Pulse Survey and focus groups on the added pressures staff are under due to headcount pressures; a perceived lack of strong visible leadership in DCMS and that comments and thoughts are asked for but not acted on.

The Diversity network raised the issue that diversity work had seem to have slipped down the priority list following the transformation of Corporate Services. This has now been addressed with a clear lead in HR on internal diversity policy and a clear lead in the Programmes team on diversity issues raised in policy development. It will need to be monitored however to ensure the priority does not slip again.
Staff Survey

A key strand of the work of the transformation programme has been to run a programme of consultation and evidence gathering with staff across the department including staff workshops and the Staff Opinion Survey which was conducted in June 2007.
After the all-staff conference in October, 128 staff were asked to take part in an online survey. Participants were chosen at random to make up a sample representative of grade and division across the department. The survey sample was, where possible, checked to ensure it was representative (of the Department's staff) in terms of gender, age, working pattern, disability and ethnicity.

Respondents were asked for their opinions on a number of key questions that help to monitor how the transformation programme is proceeding.  Results were only published at the overall level for DCMS and not for individual equality groups, though some comments were made by respondents that related to diversity in the department in general.
The survey will be run every three months with the same panel of respondents so that we can measure shifts in attitudes as we move forward. This will ensure that the programme of change will continue to be informed by DCMS staff and that any specific concerns are picked up by the change team.

Update – July 2009
The pulse survey has continued to be run over the last two years and we are on wave 6. Since April 2009 we have supplemented the Pulse survey with focus groups in order to get qualitative data on staff views.
Possible Opportunities

Whilst there were concerns around some potential adverse impacts on groups of people, staff were also keen to emphasise the potential opportunities the transformation programme could bring. Specifically, if handled correctly, it would be a chance for all members of staff to see positive changes with respect to training opportunities, IT resources and being able to work in more challenging roles. It was felt that the programme could offer staff from a diverse range of groups the opportunity to work on new projects and priorities; something that staff felt was not currently the case. HR’s role could be re-defined to support organisational development, talent management and improved line management competence.
There was a view that for cultural reasons some BME staff might not have the confidence to put themselves forward for new jobs or new development opportunities. The transformation would be an opportunity to get access to training courses such as PRINCE2 and Managing Successful Programmes.
The transformation of DCMS could be an opportunity to revamp the current flexible working patterns and remind senior managers and staff of the benefits of flexible working, as well as exploring advantages around flexible working patterns (for example, compressed hours or flexi-time). It was felt that the attitude of senior staff would be key in ensuring that flexible workers were not adversely affected by the transformation programme. However, great care would also need to be taken to ensure that the transformation programme does not discriminate against other groups among staff.
Some staff felt that the programme would be a real opportunity to increase the department’s capacity to improve the facilities available for flexible working patterns (for example, improving our IT provision, including Broadband access). It was recognised that while this option would need a significant upfront investment this could be more than balanced by the benefits and efficiency savings.
Actions Going Forward

During the course of speaking to staff members at this early stage, there is no evidence to suggest that the transformation programme plans will have an adverse impact on equality grounds; indeed there was a perception that the Transformation programme could offer improvements for equality of opportunity. Given the lack of further detail at this time, more research will be needed.  
However, a number of risks were identified by staff and there are some concerns around access to opportunities for some of the staff mentioned.  Actions listed below will be built into the change programme to mitigate the risks:

1.	The change team will build in a specific project around the capability of IT resources and how they can be delivered so as to help flexible workers (Mark O’Neill)
2.	The change team will work closely with HR to ensure that the new talent management strategy reflects the needs of a diverse range of staff (Carol Carpenter)
3.	HR should review its diversity policies, including any actions within the statutory Race, Disability and Gender Equality Schemes, with the aim that recruitment and development strategies will improve the diversity of the workforce across DCMS (HR)
4.	The learning and development strategy will offer staff access to a wide range of training opportunities (for example, PRINCE2 and line management, where appropriate) (HR)
5.	HR can review the support mechanisms to help staff to during the Transformation Programme, including briefing the Employment Assistance Programme about the change (Helier Cheung)

Other proactive work includes:

6.	Developing case studies on flexible working patterns to support the business case for home working and help managers develop their skills and confidence and reap the benefits of the range of effective flexible working patterns (Flexible Workers Network)
7.	Continuing work on ensuring the fair allocation of performance bonuses (HR)
8.	Ensure that managed moves do not lead to adverse impact on particular groups (HR)
9.	Encourage all staff to take up opportunities for mentoring and secondments (HR, line managers and diversity networks to promote opportunities)

Update - November 2008
No specific adverse impact on equality grounds has been identified by the staff we have spoken to. However there are a number of questions about the process and some concerns around access for some staff mentioned. As the process continues we will need to continue to monitor it closely to ensure that some groups of staff are not being adversely affected.
Actions listed below will be built into the corporate services change programme to mitigate the risks:
10.	The first five actions set out above have been taken forward in some cases but the newly structured HR will be able to mainstream these actions much more, and therefore they will be taken forward as part of the corporate services change project.
11.	The change team and HR will work with the Heads of CS team and the CS Director to ensure that all CS staff receive the support that they need through this process – particularly redeployment, including running a series of workshops for CS staff. (Helier Cheung)
12.	The change team and Heads of CS team will ensure that all staff are regularly updated on the change project in the level of detail relevant to their role. (Claire Macaulay)
13.	The change team and the Head of HR will work together to ensure that there is sufficient resourcing to carry out the department’s responsibilities in terms of diversity. (HR) 
14.	The change team will monitor the staff allocation process to check that the outcomes are not affecting any groups of staff in adverse ways, and will communicate with the Diversity Network at key points throughout the process. (Alan Sutherland)

Update – October 2009
Again, no specific adverse impact on equality grounds has been identified by the staff we have spoken to. As the process continues we will need to continue to monitor it closely to ensure that some groups of staff are not being adversely affected.

Action 1 is currently being worked on though the tech refresh and the accommodation project; actions 2-4 have been mainstreamed into the work of HR and are not being taken forward by the Change Team and action 5 is completed, following a programme of work in the run up to March 09. Actions 6-9 have also been mainstreamed into the work of HR and are not being taken forward by the Change Team. Actions 10 -14 have been completed. There are no new specific mitigation actions in place for the current phase of the change programme.
Review

We will review the impact of the programme at critical phases. The next major milestone is the second all staff conference on 5 February 2008, where it is anticipated that staff will be given further details about the structure of the department (for example, which one of the four areas their work will fall into). At that stage, the change team will consult the diversity networks and the Trade Unions again to seek out their views on whether any of the risks identified above are being realised, or if any new risks have emerged and to explore further potential equality gains from the programme.

Update -November 2008 
We will continue to review the impact of the change programme at critical phases. The next major milestone will be the completion of the recruitment exercise for corporate services staff on 19 December 2008. At that stage, the change team, will consult the diversity networks and the trade unions to seek their views on whether any of the concerns they have raised are coming to the fore, or if any new risks have emerged, and if so how best to address these.

Update- October 2009
The Capability re-review check in March 09 was a chance to review the programme overall and a number of changes were made as a result of the re-review process. These changes included introducing 16 new projects as part of the action plan, with 6 priority projects. These projects were programme managed by the Change Team but the delivery is the responsibility of the Project Owner, which in most cases was the Director of the relevant business area. We will also review the process following the Health Check undertaken b y the Cabinet Office during October 09 and make any necessary changes or amendments to the programme. Depending on the outcome of the review we will look at how to further mainstream the change programme back into the business.
Appendix A:	Flexible Organisation

Appendix B:	Evidence Gathering Workshops

Meeting with the Diversity Network
Held on: Monday 19 November
Attendees: 10 members of staff, 2 colleagues from the Royal Parks
Expressing views on all strands covered by this EIA

Meeting with the BME Network
Held on: Friday 23 November
Attendees: 8 members of staff
Expressing views on the race strand

Meeting with the Flexible Workers Network
Held on: Monday 26 November
Attendees: 7 members of staff
Expressing views on the gender strand

Meeting with Diversity Network
Held on: Tuesday 9 September 08
Attendees: 7 members of staff
 Expressing views on the emerging findings of the corporate services work and the approach to the next phase of the project; no comments were raised

Meeting with Diversity Network
Held on: Wednesday 5 November 08
Attendees: 10 Members of staff
Expressing views on the corporate services consultation documents 

Written consultation with Diversity Network
Held from : 21 October to 6 November
Responses: 3 members of staff
Expressing views on changes added as a result of the Capability Action Plan and latest phase of Corporate Services change.

Appendix C:	Staff Breakdown
DCMS Staff breakdown at 30 March 2009

Disabled staff

Grade	Staff in Post	Not stated	Prefer not to say	Disabled	%	
SCS	44	10			0	
A(U)	22	2	1	1	5	
A	106	6		3	3	
HEOD	15	5			0	
B	154	11		3	2	
C	94	10	1	4	5	
D	32	4		2	7	
Total	467	48	2	13	3	

Female Staff

Grade	Staff in post	Female	%	
SCS	44	18	41	
A(U)	22	9	41	
A	106	51	48	
HEOD	15	7	47	
B	154	70	45	
C	94	46	49	
D	32	18	56	
Total	467	238	47	

Number of Part-time workers
Grade	Staff in post	Part-time	%	
		M	F		
SCS	44	1	3	9	
A(U)	22	0	4	18	
A	106	3	10	12	
HEOD	15	1		7	
B	154	4	9	8	
C	94	3	7	11	
D	32	0	4	13	
Total	467	12	37	10	

The number of staff set-up to work from home is 15.

2-4 Cockspur Street
London SW1Y 5DH
www.culture.gov.uk

Ethnic Minority Staff
Grade	Staff in post	Not declared	Ethnic minority	%	
SCS	44	12	2	6	
A (U)	22	4	0		
A	106	14	5	5	
HEOD	15	4	4	36	
B	154	14	20	14	
C	94	15	12	15	
D	32	2	9	30	
Total	467	65	52	13	

Number of staff by age

Grade	24-	25-29	30-34	35-39	40-44	45-49	50-54	55+	Count	
SCS	0	0	2	1	10	8	9	9	44	
A(U)	0	1	0	2	3	4	5	5	22	
A	0	11	17	9	15	14	12	7	106	
HEOD	4	6	3	1	0	0	0	0	15	
B	1	24	32	24	34	24	10	13	154	
C	3	17	21	14	16	10	12	9	94	
D	1	5	5	2	8	7	4	5	32	
Total	9	64	80	53	86	67	52	48	467