Equality Impact Assessment

Equality Impact Assessment Toolkit

Section 1:

EIA lead Officer: Joanne Barrett

Email address: joannebarrett@wirral.gov.uk

Date: August 2025

 

Section 2: 

What Council proposal is being assessed?

All Local Housing Authorities, including those who no longer manage or own any social housing stock, are required to have in place a Housing Allocation Scheme (HAS), providing detailed information about all procedures that will be followed, and by which persons, in the allocation of Social Rented Housing within their local authority (LA) area.

Statutory guidance reminds LAs they must have regard to their duties under equalities legislation when framing their allocations qualification criteria within the HAS. This Equality Impact Assessment is based on the HAS known as Property Pool Plus (PPP) being implemented on 18th August 2025, which includes updates to the previous version of the scheme which was implemented in January 2024.

The Local Authority intends to allocate homes in a fair, lawful and transparent way, that makes best use of the homes available. The HAS will set out how the Local Authority will allocate social rented housing to those persons applying to become a social housing tenant; and secure tenants seeking to move to another home let under secure tenancies.

The PPP Policy explains how priority for rehousing between applicants will be determined and the arrangements for nominating applicants for homes owned by private registered providers of social housing (PRPs) who own and/or manage social rented housing in the LA area.

Section 3: 

Does the proposal have the potential to affect (please tick relevant boxes)

¨         Services

¨         The workforce

X         Communities

¨         Other (please state eg: Partners, Private Sector, Voluntary & Community Sector)

Section 4:

Could the proposal have a positive or negative impact on any protected groups (age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; sexual orientation)?

You may also want to consider socio-economic status of individuals. We encourage services to consider the impact on those who serve and who have served in the armed forces and their families, in accordance with the Armed Forces Covenant

Please list in the table below and include actions required to mitigate any potential negative impact.

 

Table showing potentially positive and negative impacts of the Property Pool Plus policy on protected groups.

 

Which group(s)   of people could be affected

 

Potential positive or negative impact

 

Action required to mitigate any potential negative impact

Age

 

 

Positive impact. 

Provision within Band A for Victims of hate crime amounting to violence or threats of violence due to their age.

Sheltered and extra care housing is targeted specifically at older people, usually from 55 and upwards.

Young applicants who have been looked after, accommodated or fostered by any local authority as part of the performance of its children social care duties by the LA will be exempt from local connection requirements when preparing to leave the care arrangements so that they can apply for a social rented home in their area of choice.

Young applicants leaving the care of one of the scheme local authority children’s services for the first time are awarded Band A, which is backdated to their 16th birthday. There is also provision to award band A for subsequent moves due to housing need.

Young applicants defined as a Child in Need in accordance with the Children’s Act 1989 section 17 who are resident in homeless commissioned supported accommodation can get Band A which can be backdated to the date they moved into that accommodation.

The savings qualification criteria for joining the scheme includes a disregard for those who are unable to leave hospital due to the unsuitability of their existing home, in certain circumstances. Some of those impacted by this criteria are likely to be older people.

N/A

 

Disability

 

 

 

Positive impact.

Provision within Band A for:

  • those whose medical condition is life threatening, and their existing accommodation is a major contributory factor;
  • those whose medical condition is expected to be terminal, and rehousing is required due to detrimental effects caused by the present accommodation;
  • those whose planned discharge from hospital is imminent and there is no accommodation available to them which is reasonable for them to occupy;
  • victims of hate crime amounting to violence or threats of violence due to their disability, where continued occupation of the current dwelling could place lives at risk.

Provision within Band B for:

  • those needing to move due to a disability of any member of the household.
  • victims of hate crime amounting to violence or threats of violence due to their disability.

Specific arrangements will be considered for each individual applicant and property where it may be accessible, informing an applicant of a property’s accessible features and implementing a mechanism to identify the requirements of disabled applicants, to allow extra time for disabled applicants, if they need it, to accept an offer and for providing support in making applications.

Properties advertised through the scheme which have been adapted to meet the needs of those with disabilities are advertised giving preference to applicants with a verified need for an adapted property.

Applicants who can prove they have a continuing caring responsibility for someone who is resident in the scheme area, and that this care could not be provided unless they were resident in the region, will be exempt from local connection qualification requirements.

Disregards to the home ownership qualification criteria in certain circumstances for those whose household includes a severely disabled person requiring a move to a substantially adapted property.

The savings qualification criteria for joining the scheme includes a disregard for those who are unable to leave hospital due to the unsuitability of their existing home, in certain circumstances. Some of those impacted by this criteria are likely to be disabled people.

N/A

 

Gender

Reassignment

 

 

 

 

Positive impact.

Band A and B includes provision for those who need to move due to being victims of hate crime amounting to violence or threats of violence due to gender reassignment.

The bedroom standard includes provision to consider on a case by case basis the award of an additional bedroom due to gender identity.

N/A

 

Marriage and Civil Partnership

 

 

 

Positive impact.

Band A and B include provision for those who need to move due to being victims of hate crime amounting to violence or threats of violence due to their marriage or civil partnership.

N/A

 

Pregnancy and maternity

Positive impact.

Band A and B includes provision for those who need to move due to being victims of hate crime amounting to violence or threats of violence due to their pregnancy or maternity.

Unborn children are included in the bedroom calculation from the point the matb1 certificate is issued.

N/A

 

Race

Positive impact

Band A and B includes criteria for those who need to move due to being victims of racial harassment amounting to violence or threats of violence, and victims of hate crime due to their race.

The qualification criteria for local connection includes exemptions for:

  • Homeless households who have been newly granted refugee status and are owed a Homelessness Duty by one of the scheme local authorities, and
  • Households placed in one of the scheme local authority areas under the ‘Homes for Ukraine Scheme’.

Essential and appropriate checks which are carried out to establish an applicant’s eligibility to be allocated social rented housing will be monitored to ensure that they are not discriminatory on the basis of race, nationality, ethnic origin, or any other protected characteristic.

N/A

 

Religion or belief

Positive impact.

Band A and B includes provision for those who need to move due to being victims of hate crime amounting to violence or threats of violence due to their religion or belief.

N/A

 

Sex

The procedure does not contain specific provision which positively discriminate due to gender, although the gender of each member of an applicant household is fully considered during the assessment process regarding the size and type of accommodation that would be suitable, due to children over a certain age not having to share a bedroom with a child of a different sex.

N/A

 

Sexual orientation

Positive impact.

Bands A and B include provision for those who need to move due to being victims of hate crime amounting to violence or threats of violence due to their sexual orientation.

N/A

 

Domestic abuse victims.

Positive impact.

Band A and B include provision for those who need to move due to domestic abuse.

The scheme qualification criteria includes disregards to the local connection, home ownership and rent arrears criteria for those who need to move due to domestic abuse.

N/A

 

Armed Forces

Positive impact.

Band A includes provision to assist members, and former members of the armed and reserve forces who are in housing need. This provision also extends to bereaved spouses and civil partners of members of the Armed Forces leaving Services Family Accommodation following the death of their spouse or partner, which was wholly or partially attributable to their service.

The scheme qualification criteria includes a disregard to the local connection element for certain Armed Forces personnel and members of the armed forces community.

The scheme qualification includes a disregard to the savings criteria for compensation payments received for an injury or disability sustained on active service.

The scheme discretion criteria includes a point which states that discretion can be used where a member of the Armed Forces community has been disadvantaged in respect of their ability to access suitable housing through their own or their family member’s service in the Regular Armed Forces or Reserve Forces.

N/A

 

All

Positive Impact.

 

The discretion criteria includes scope to assist individual cases with an exceptional and urgent welfare need for rehousing which is not specifically referenced elsewhere within the policy. This could positively impact people in any of the protected groups who have an exceptional and urgent welfare need for rehousing which is not specified in the policy, by allowing individual circumstances to fully taken account of in the assessment of their housing need.

N/A

 

All

Potential negative impact in respect of the following points which have been included in a recent policy update. These changes could negatively impact some applicants who are in the protected characteristic groups in respect to the number of property allocations to these groups. Changes include:

  • The increase in priority to Band A for those ready to move on from Local Authority commissioned / funded homeless provision of supported housing / hostels
  • The local authorities have the option to implement a period of direct matching for a proportion of properties to key groups.
  • The local authorities have the option to implement pilot trials of new ways of working to inform future service delivery and potential scheme improvements to resolve housing need.
  • Implementation of a 5% net cross boundary mobility cap to ensure that the majority of properties in any local authority area are allocated to residents of that area.

 

 

Any negative impact from the recent changes are likely to be mitigated by the following points which will be monitored quaterly by the LCR CBL Lead and Contract Board:

  • Care Leavers receive a backdate to the Band A award to their 16th birthday which affords an extra advantage which will limit any impact of these changes.
  • Those applicants moving into Band A under the recent changes will be mainly one bedroom need applicants who will not be competing for larger properties thereby limiting the impact on applicants requiring properties with 2+ bedrooms.
  • Some of those in Band A for reasons linked to health / disability may require specific types of accommodation such as properties with adaptations. Properties of this type are advertised giving preference to those who need these facilities.
  • In respect of direct lettings, it is likely  that those receiving a direct let will include some applicants who are in the protected characteristic groups.
  • Properties which are adapted would not be direct matched to applicants who do not need the adaptations.
  • The impact on those who need / wish to move to sheltered accommodation and are aged 55+ is limited due to the restrictions on allocating sheltered accommodation to those aged 55+.
  • Those in the highest housing need will still have a high priority based on the urgency of their situation so may still receive an offer of accommodation regardless of the recent changes.
  • Some Armed Forces cases and all those with a priority for a move due to domestic abuse receive a local connection and relative priority for all scheme local authority areas thereby affording additional opportunity for rehousing.
  • Exemptions to advertising properties giving preference to local authority residents under a 5% cap will be afforded to some members of the Armed Forces community, Domestic Abuse victims and Care Leavers.
  • Anyone in Band B whose urgency for a move escalates may be reassessed and awarded Band A subject to meeting relevant criteria.
  • Anyone registered with the scheme who is at risk of becoming homeless or who becomes homeless can seek assistance from the relevant homelessness service, which may impact the level of priority, and the type of assistance provided.
  • Implementation of a period of direct lettings will be subject to a separate equality impact assessment.
  • Quarterly reporting and monitoring will be undertaken to monitor any adverse impact of the recent changes.

 

 

 

Section 4a:    

Where and how will the above actions be monitored?

Quarterly monitoring via Liverpool City Region Property Pool Plus Contract Board.

Section 4b:

If you think there is no negative impact, what is your reasoning behind this?

There are potential negative impacts as outlined in the document, these will be monitored. There are also several mitigating factors detailed in the document. Any potential for negative impact will be monitored as outlined above.

Section 5:

What research / data / information have you used in support of this process?

Property Pool Plus housing register and allocations data.

Section 6:

Are you intending to carry out any consultation with regard to this Council proposal?

Yes – Consultation has already taken place see further detail in section 7

Section 7:

How will consultation take place and by when?

A full public consultation exercise was completed prior to the policy being launched in January 2024. A further four-week consultation exercise was completed in January 2025 in relation to some policy changes made to the policy which were implemented on18th August  2025. This was with existing Property Pool Plus applicants, Registered Provider landlords who allocate their accommodation through the scheme and other partner organisations. The responses to both consultations have been taken into consideration in final approved policy.

Before you complete your consultation, please email your preliminary EIA to engage@wirral.gov.uk via your Chief Officer in order for the Council to ensure it is meeting it’s legal publishing requirements. The EIA will need to be published with a note saying we are awaiting outcomes from a consultation exercise.