PSO 2800 - Inside Time

PrisonServiceOrderRACE EQUALITYORDERNUMBER2800List of ContentsDate of Initial Issue 25/09/06Issue No. 264PSI Amendments should be read in conjunction with this PSODate of FurtherAmendments

PSO 2800 Page 1EXECUTIVE SUMMARYSTATEMENT OF PURPOSEThe revised version of PSO 2800 consolidates a number of substantial changes in themanagement of race equality, including the changes introduced in PSI 46/2001 and PSI37/2005. It introduces a number of new terms and procedures designed to ensure compliancewith the Race Relations (Amendment) Act 2000 and to improve the management of race equalityin establishments.DESIRED OUTCOMEThe revised PSO is designed to ensure that the management of race equality is better integratedinto core business, and that there is a focus on outcomes, rather than processes. In order toachieve this there is much less central prescription and much greater local accountability.Central to the revised PSO are improved management structures in establishments, in the formof Race Equality Action Teams, reporting quarterly to Senior Management Teams, Governorsand Area Managers. All members of these teams must be engaged in ongoing work on themanagement of race equality in their functions and areas. Those taking on the new role of RaceEquality Officer must be used to support the work of these teams.MANDATORY ACTIONSMandatory actions appear in italicsRESOURCE IMPLICATIONSThere will be resource implications for many establishments, particularly those where there iscurrently no full-time Race Equality Officer. This impact will to some degree be mitigated by themore effective use of management time that is facilitated by the shift in focus from processes tooutcomes, and the associated reduction in central prescriptionIMPLEMENTATION DATE: 25 September 2006Phil WheatleyDirector General.Further advice or information on this PSO or the systems contained within it can be soughtfrom:The REAG Helpdesk can be used by any member of staff as a first point of enquiry in connectionwith the work of the Group. . Contact details are as follows:Helpdesk telephone: 020 7217 2521Helpdesk e-mail: reag@hmps.gsi.gov.ukIssue No. 264 Issue date 25/09/06

PSO 2800 Page 2CONTENTS1. Introduction2. Legal Obligations3. Management of Race Equality in Establishments4. Management Information5. Impact Assessments6. Racist Incidents7. Community Engagement8. Training9. Communication10. Management of Race Equality above Establishment LevelAnnexes1. Model Terms of Reference for the Race Equality Action Team2. Model Job Description and Core Competences for the Race Equality Officer3. List of Areas for Impact Assessment4. Impact Assessment Screening Tool5. Full Impact Assessment Template6. Guidance on Consultation for Impact Assessments7. Guidance on running Focus Groups8. Racist Incident Reporting Form9. Community Engagement Evaluation Template10. Community Engagement Strategy TemplateIssue No. 264 Issue date 25/09/06

PSO 2800 Annexes – Page 3CHAPTER 1 – INTRODUCTION1.1 This introduction gives an overview of the PSO and the structure that it sets out to allow thePrison Service to meet its legal responsibilities.1.2 Our policy statement sets out our intent:The Prison Service has a positive duty, and is committed, to: eliminate unlawfuldiscrimination; promote equality of opportunity; and promote good relations between peopleof different racial groups. Unlawful discrimination on the basis of colour, race, nationality,ethnic or national origin, or religion is prohibited, as is any racially abusive or insultinglanguage or behaviour on the part of any member of staff, prisoner or visitor. Action will betaken against anyone who contravenes this policy statement.1.3 In order to make good this intent, prison establishments must work to ensure that:Direct discrimination, harassment, victimisation and incitement to racial hatred areprevented and tackled and good relations between people of different racial groupspromoted;Indirect discrimination is prevented and tackled and equality of opportunity promoted.This order outlines Prison Service policy in each of these areas. Establishments mustcomply with this policy, and devise a programme of work (the Race Equality Action Plan –REAP) to take it forward locally.Direct Discrimination and Promotion of Good Race Relations1.4 The first area refers to the actions of individuals and groups. Establishments must work toeradicate discrimination and harassment by informing staff of their responsibilities andproviding them with other relevant training (chapter 8) and by putting in place an effectivecomplaint system that includes measures to identify and tackle perpetrators and to protectcomplainants (chapter 6). Establishments must work to promote good race relations bycommunicating with staff, prisoners and visitors (chapter 9) and engaging with the localcommunity (chapter 7).Indirect Discrimination and Promotion of Equal Opportunity1.5 The second area is not about the actions of individuals and groups, but about policies andpractices that disadvantage particular groups. When prevalent within an organisation thiskind of indirect discrimination can lead to what has been termed institutional racism – acollective failure that is the result of discrimination through unwitting prejudice, ignorance orthoughtlessness, and racist stereotyping.1.6 The main tool in addressing this area is the assessment of the impact of all policies andprocedures on different racial groups, and the process for doing this is set out in chapter 5.From this impact assessment process establishments must derive action plans to addressindirect discrimination and to promote equality of opportunity in the operation of particularpolicies and practices, and these must become part of the Race Equality Action Plan.1.7 In order to ensure that impact assessments are conducted effectively, establishments needto ensure that monitoring procedures are in place (chapter 4) and that there are appropriatemethods of consulting and communicating with staff, prisoners and visitors (chapter 9) andthe wider community (chapter 7).Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 4Management1.8 The structure for managing the above processes and the Race Equality Action Plan inestablishments is set out in chapter 3.1.9 The management structure and support available above establishment level – at area leveland in headquarters – is set out in chapter 10.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 5CHAPTER 2 – LEGAL OBLIGATIONS2.1 This section sets out the personal and corporate responsibilities of Prison Service staffunder the Race Relations (Amendment) Act 2000.Background: The Race Relations Act 1976 (1976 Act)2.2 The 1976 Act outlawed discrimination on racial grounds in employment, training, housing,education, and the provision of goods, facilities and services. However, a narrowinterpretation of „services‟ meant that many public functions were not covered.The Race Relations (Amendment) Act 2000 – RR(A)A 20002.3. The RR(A)A 2000 introduced a range of positive duties on public authorities. Theobligations that it places on the Prison Service are:the general duty to:(a) eliminate unlawful racial discrimination;(b) promote race equality;(c) promote good relations between people of different racial groups;the specific duties to publish a Race Equality Scheme that sets out which of our functionsand policies are relevant to race equality and how we will:(a)(b)(c)(d)(e)assess and consult on the likely impact of proposed policies on thepromotion of race equality;monitor our policies for any adverse impact on the promotion of raceequality;publish the results of our impact assessments, consultation and monitoringto show how we have taken account of race equality issues in makingpolicies;ensure public access to information about services, functions and activities;train our staff to carry out the general and specific duties.We also have a specific duty relating to the treatment and employment of staff that requires us tomonitor how our employment practices affect staff of all racial groups within the Prison Service.Prison Service Race Equality Scheme (RES)2.4 The Prison Service Race Equality Scheme (RES) is an Associate Scheme of theoverarching Home Office Race Equality Scheme. It is published every three years and setsout what the Prison Service will do to meet the general and specific duties.2.5. An annual report on progress on the measures set out in the RES is published.Responsibilities of Staff2.6. All staff in the Prison Service are bound by the general and specific duties set out in theAct, whether they are involved in policy development, service delivery or the provision ofsupport services. The duties apply also to agency staff and staff on secondment from otherorganisations as well as those working for other companies, contractors or voluntary andcommunity groups providing services within prisons.2.7. It is the duty of every member of staff to work to eliminate unlawful racial discrimination, topromote race equality and to promote good relations between people of different racialgroups. This must be demonstrated as a fundamental, integral part of the daily work of allmembers of staff.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 6CHAPTER 3 – MANAGEMENT OF RACE EQUALITY IN ESTABLISHMENTS3.1 Implementing the Service's race equality policies is an integral part of the day-to-dayresponsibilities of staff at all levels. All staff working in the Prison Service are bound by thegeneral and specific duties under the Race Relations (Amendment) Act 2000. These dutiesare set out in Chapter 2.3.2 Although race equality is everyone‟s business, in establishments there are keymanagement functions that must be fulfilled by the Governor and the Senior ManagementTeam (SMT). The Governor must provide active personal leadership and set a clearpositive example. Functional heads must take personal responsibility for race equalitywithin their areas and it should be a routine agenda item at SMT with formal discussion atleast quarterly.3.3 The Governor must establish a sub-group of SMT, known as the Race Equality ActionTeam (REAT), to manage the establishment’s Race Equality Action Plan (REAP). TheRace Equality Action Team must meet regularly and submit a formal report to the SMT atleast quarterly.3.4. Whilst delivery of the Race Equality Action Plan is the responsibility of all staff, andmanaged by the Race Equality Action Team, Governors must appoint a Race EqualityOfficer (REO) to take the lead role in this work. Appropriate support must be provided forthe Race Equality Officer.3.5. The Race Equality Action Plan must set out a programme of work derived from this orderand other relevant sources and constitutes a comprehensive plan of action that is managedby the Race Equality Action Team. It must be updated by the SMT quarterly, with a reporton progress being sent to the Area Manager and copied to Race Equality Action Group.The Role of the governing GovernorThe Governor must provide active personal leadership and set a clear positive example.3.6. The Governor has overall responsibility for race equality for all staff and prisoners within theestablishment. Governors carry the primary responsibility for ensuring that the Service‟sRace Equality Policy Statement is implemented in practice, and that the general andspecific duties under the RR(A)A 2000 are met by all staff. Governors must also provideactive personal leadership to ensure the effective delivery of their establishment’s REAP.In doing so they must set a clear positive example in their own behaviour and attitudes.3.7. Governors are responsible for integrating the management of race equality into the generalwork of the establishment, ensuring that it is included in all relevant managementprocesses such as business planning and risk registers.The Role of the Senior Management TeamFunctional heads must take personal responsibility for race equality within their areas and it mustbe a routine agenda item at SMT with formal discussion at least quarterly.3.8. The Governor will be supported by the SMT. SMT members have a role to play indelivering race equality, both within their specific area of responsibility and across theestablishment. The SMT must receive and discuss the quarterly report from the RaceEquality Action Team, and agree any resulting changes to the Race Equality Action Plan, atleast quarterly.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 7The Race Equality Action TeamThe Governor must establish a sub-group of SMT, known as the Race Equality Action Team(REAT), to manage the Race Equality Action Plan (REAP). The Race Equality Action Team mustmeet regularly and submit a formal report to the SMT at least quarterly.3.9. The leadership, membership, terms of reference and frequency of meetings of the RaceEquality Action Team must be set by the Governor.3.10 The leader of the Race Equality Action Team must be the Governor or the DeputyGovernor. Membership must include relevant functional heads as well as the RaceEquality Officer and representatives from:the Chaplaincy team;the Education provider;the health care provider;the voluntary and community groups working with the prison; andprisoner representatives.A member of the Independent Monitoring Board may also attend meetings of the REAT asan observer.3.11 Model terms of reference for meetings of the REAT are provided at annex 1. These shouldbe adapted to meet the particular needs of each establishment.3.12. The REAT must meet regularly with minuted meetings. It may be helpful for meetings totake place monthly to ensure that there is prompt consideration of and action taken onmonitoring data. A record of the meetings should be incorporated into the quarterly reportto the SMT.3.13. The REAT will provide a clear positive lead on the operational management of raceequality, including the management of the REAP. Whilst REAT meetings are important,they should by no means be the only time at which REAT members are engaged in work onrace equality issues. Much of the work of the REAT should take place outside of themeeting, with individual members and sub-groups taking forward the work identified in theREAP. In particular, functional heads are responsible for taking forward the REAP in theirareas of the prison, as well as attending and contributing to REAT meetings.3.14. Governors must ensure that Race Equality Action Team members, including prisoner andvoluntary and community sector representatives, are adequately skilled to perform theirduties, and that a record is maintained of relevant training undertaken by Race EqualityAction Team members.3.15. Driving forward delivery on race equality requires a combination of general managementcompetences as well as an understanding of and commitment to the diversity agenda.Race Equality Action Team members must set a positive personal example andcommunicate clear messages to their staff about their responsibility to do likewise.Amongst other things they need to be:aware of the sensitivities around racist incident reports and investigations;able to analyse ethnic monitoring data; andable to identify positive, practical actions to address local issues.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 8The Race Equality OfficerGovernors must appoint a Race Equality Officer (REO) to take the lead role in the programme ofwork on race equality.3.16. The Race Equality Officer‟s main role is to support the Governor and the Race EqualityAction Team in taking forward the programme of work to achieve compliance with this orderand the RR(A)A 2000. In addition the Race Equality Officer provides a central point ofcontact for staff and prisoners seeking information on legislation, policy and practicerelating to race equality.3.17 Whilst the Race Equality Officer takes the lead on the programme of work, it is not theresponsibility of the Race Equality Officer to undertake all the work. This should beallocated to relevant managers and staff. For example, impact assessments shouldgenerally be conducted by a group of staff managed by the relevant functional head,advised by the Race Equality Officer. The Race Equality Officer must not be given leadresponsibility for them or be required to conduct them alone.3.18 A model job description and core competencies for the role of Race Equality Officer isattached at annex 2. In most establishments it is likely to be a full time role. Where this isnot considered to be necessary the Governor must agree alternative arrangements with theArea Manager. REAG will retain a record of such decisions.3.19 The Race Equality Officer must be appointed by the Governor in accordance with the equalopportunities (PSO8010) and filling vacancies (PSO8110) policies. In order to ensure theappointment of an individual with the specialist skills required for the post, considerationshould be given to recruitment from outside of the Prison Service. If it is decided to useexternal recruitment, establishments must comply with the relevant policy (PSO8100 – theRecruitment website). It may be appropriate to involve an external person, such as thevoluntary and community sector representative on the REAT in the selection process.Alternatively, a manager from elsewhere in the Prison Service, such as a member of stafffrom REAG, the Area Diversity Manager / Advisor, or an experienced Race Equality Officerfrom another establishment, could be involved in the selection process.3.20. In establishments that have appointed Diversity Managers, it should be clear whether or notthis individual is also the Race Equality Officer. Where the two roles are combined,Governors must ensure that there is sufficient support in place for the post holder for all ofthe duties of both roles to be completed. Where the two roles are distinct, the respectiveduties of each post should be made clear.Appropriate support must be provided for the Race Equality Officer.3.21. Where elements of the race equality work require specific skills, such as the statisticalanalysis of monitoring data, or are more suitably undertaken by administrative staff ratherthan a manager, appropriate support for the Race Equality Officer should be put in place.For example this may involve some tasks being taken on by the audit, secretariat orpsychology department. Where this is the case, these duties should be reflected in thebusiness plans of the relevant departments and the Staff Performance and DevelopmentRecords (SPDRs) of the individuals concerned.3.22. It is good practice, particularly in larger establishments, to appoint Assistant Race EqualityOfficers on each wing or house block to act as a link between prisoners and the RaceEquality Officer. Assistant Race Equality Officers should be appointed by the leader of theREAT. Their duties should be agreed between the leader of the REAT and their linemanagers and included in their SPDRs. Appropriate time should be made available forthem to complete these duties.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 9The Race Equality Action PlanThe REAP must set out a programme of work derived from this order, the associatedPrison Service Standard and other relevant sources including:Impact assessments;Race Equality Key Performance Targets;SMART monitoring data;Quarterly Questionnaire data;Measuring the Quality of Prison Life data;Visitor survey;Complaints and Racist Incident Reporting Forms and associated investigations;Community engagement strategy;Communications strategy;HM Chief Inspector of Prisons and Independent Monitoring Board reports;Visits from the Race Equality Action Group Service Delivery and ImplementationTeam.3.23. This plan must be managed by the Race Equality Action Team.3.24. The Race Equality Action Team must report on the Race Equality Action Plan to the SeniorManagement Team quarterly, and the written report must be sent to the Area Manager andcopied to Race Equality Action Group.3.25. A formal Annual Report on the management of race equality in the establishment, including anupdate on the REAP, must be published and made available to staff, prisoners, visitors andother stakeholders.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 10CHAPTER 4 – MANAGEMENT INFORMATION4.1 This chapter sets out the range of information that should be used in conducting impactassessments and in devising and monitoring the Race Equality Action Plan4.2 The focus is on ethnic monitoring data, but relevant information should be derived from the fullrange of sources set out in chapter 3. Of particular importance are:Performance Standard;Key Performance Target information;Quarterly race equality questionnaire information;HM Chief Inspector of Prison reports;Independent Monitoring Board reports;REAG Service Delivery and Implementation Team.Ethnic monitoring4.3 Ethnic monitoring is the process used to collect, store, and analyse data about the ethnicorigin of prisoners.4.4 This chapter sets out the monitoring systems that must be used by establishments toensure that functions and policies are effectively eliminating unlawful discrimination andpromoting race equality. Consistent and accurate ethnic monitoring of key functions andpolicies will provide evidence to inform the impact assessment process. Ethnic monitoringdata is important also for the more general purpose of providing information about thecurrent state of race equality within the establishment. Without such data the PrisonService will not be able to determine the effectiveness of its Race Equality Scheme.4.5 Ethnic monitoring can be used to assess whether the Service offers equality of opportunityand treatment to all groups of prisoners. It can also tell how and why establishments andpolicy leads are not achieving this goal.4.6 Ethnic monitoring has many wider benefits. It helps establishments to use resources moreeffectively in order to improve service delivery to prisoners and avoid what could be costlycomplaints of racial discrimination, by identifying and tackling problems at an early stage. Itwill be difficult for establishments and policy leads to demonstrate they have met their dutyto eliminate unlawful racial discrimination, and promote equal opportunities and raceequality if they have inadequate monitoring data.SMART4.7 The Systematic Monitoring and Analysing of Race equality Template (SMART) programmeis used to analyse ethnic monitoring data, and information derived from it is a component ofthe Key Performance Target on race equality. SMART provides a useful tool for theanalysis of ethnic monitoring data, and gives an indication of when that analysis shouldprompt action or further investigation. It is important, however, that the Race EqualityAction Team and the Senior Management Team do not take information derived fromSMART at face value: it provides an initial analysis that should be subjected to furtherinvestigation. The information that it provides on key areas must be further scrutinised aspart of the impact assessment process.4.8. The publication of SMART data in a form that is comprehensible to staff, prisoners andvisitors is an important way of raising awareness of and confidence in the management ofrace equality in establishments and should be included in the communication strategy.4.9. Detailed guidance on SMART can be found in the Race Equality Key Performance TargetsGuidance Manual.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 11Performance Standard4.10 Regular auditing of Performance Standard 48 on Race Equality (Prisoners) providesinformation about the effectiveness of processes for the management of race equality. Theaudit score contributes to the Key Performance Target and the resulting action plan mustbe incorporated into the Race Equality Action Plan.Key Performance Target4.11 The Key Performance Target (KPT) on Race Equality (Operational) has been constructedto give an assessment that reflects a balance of processes, outcomes and perceptions.4.12 Establishments must collect a full data set for the KPT comprising the following:race equality audit score and racist incident audit score, based on Performance Standard48;Measuring the Quality of Prison Life (MQPL) - prisoner survey score;visitor survey score;ethnic monitoring data – SMART scores.4.13 Detailed information can be found in the Race Equality Key Performance Targets GuidanceManual.Quarterly Race Equality Questionnaire4.14 The quarterly race equality questionnaire is sent to establishments by Race Equality ActionGroup on behalf of the Prison Service Management Board (PSMB). It includes a series ofquestions about the key issues in the management of race equality, and these are reviewedand revised regularly. The information derived from it is used by the PSMB and AreaManagers to monitor progress in establishments and to hold Governors to account for theirperformance.4.15 Establishments must promptly complete and return the questionnaire to the Race EqualityAction Group which provides analysis of the information for the PSMB and Area Managers.HM Chief Inspector of Prisons (HMCIP) Reports4.16. HMCIP reports provide an important independent source of information about race equalityin establishments. They should be used by functional heads to provide evidence whencompleting impact assessments. Agreed actions that are relevant to race equality derivingfrom accepted recommendations in HMCIP reports should be included in the Race EqualityAction Plan.Independent Monitoring Boards (IMB) Reports4.17. IMBs report to Ministers and the community on the extent to which the Prison Service holdsprisoners in a safe, decent and healthy environment. The establishment IMB report shouldbe used as evidence in conducting impact assessments and relevant actions resulting fromrecommendations should be included in the Race Equality Action Plan.Race Equality Action Group – Service Delivery and Implementation Team4.18 The REAG Service Delivery and Implementation Team (SDIT) offers support toestablishments in managing race equality. The team uses an assessment document basedon Performance Standard 48 and seeks particularly to test outcomes, as well as processes.Actions resulting from REAG SDIT visits must be included in the Race Equality Action Plan.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 12CHAPTER 5 – IMPACT ASSESSMENTS5.1 Chapter 2 sets out the specific duties of the RR(A)A 2000 that apply to the Prison Service.As a result the Prison Service has undertaken in its Race Equality Scheme to impactassess those functions, policies and practices considered relevant to race equality and topublish the results of those impact assessments.5.2 The impact assessment process provides the means by which the Prison Service:assesses proposed and current policies for any effects they might have on the promotion ofrace equality;consults people who are likely to be affected by those policies;monitors policies for any adverse effects they might have on people from different racialgroups;takes action to correct any adverse impact found, through timed action plans.5.3 The impact assessment process is central to the management of race equality inestablishments. It is a structured method that the Governor and Senior Management Teammust use to eliminate any discriminatory effect of each of the policies and practices withinthe prison and to demonstrate their commitment to the promotion of race equality. It is aparticularly effective way for the Race Equality Action Team to promote the integration ofrace equality issues into the management of the establishment and to ensure that suchissues are considered as a routine part of all policy-making and management decisionmaking.What is an impact assessment?5.4 An impact assessment is a systematic way of finding out whether current or proposedfunctions, policies or practices affect different racial groups differently. It will helpestablishments to:take account of the needs, circumstances and experiences of those affected by PrisonService functions, policies and practices;identify actual and potential inequalities in outcomes, including unlawful racialdiscrimination;consider other ways of achieving the aims of Prison Service functions, policies andpractices in order to minimise or remove any possible adverse impact; promote equality ofopportunity and promote good relations between people of different racial groups;increase public confidence in the fairness of Prison Service functions, policies andpractices.What makes a good impact assessment?5.5 A good impact assessment is a clearly thought out and evidenced analysis of theimplications of the policy for each of the general duties of the RR(A)A. It should include:a screening stage to assess relevance to race equality;evidence that race equality has been considered at all stages of the policydevelopment process;description, discussion and analysis of relevant evidence including where availablethe most recent ethnic monitoring data;information about the methods used for consultation with prisoners, staff and thevoluntary and community sector and discussion of the outcomes thereof;a conclusion as to the actual or potential impact on people of all racial groups;a named and time bound action plan that sets out the way in which any adverseimpact will be addressed and how equality of opportunity and good relationsbetween people of different racial groups will be promoted. This action plan shouldbe clearly linked to the establishment‟s Business Plan and Race Equality ActionPlan.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 135.6. Impact assessments must be publicly available. For this reason, they should be written inplain language and should not include abbreviations and technical terms that areunintelligible to the layperson. Establishments must consider how to publish their impactassessments, and as a minimum they must be readily available to any member of staff,prisoner or visitor who requests a copy.Who should be responsible for conducting impact assessments?5.7. Impact assessments must be a part of the general policy-making and managementdecision-making processes in the prison. As such, each impact assessment must be theresponsibility of a relevant manager, usually the functional head responsible for the policyor function to which it refers. The Race Equality Officer will provide advice on impactassessments, and the Race Equality Action Team must consider completed impactassessments, but the responsibility for their completion must rest with a relevant manager,and not with the Race Equality Officer.What must be impact assessed?5.8. In accordance with the RR(A)A, all functions or policies of the Prison Service that areconsidered relevant to race equality must be impact assessed. In this context, a 'function'is any activity of the Prison Service, and a 'policy' is any prescription, whether formal orinformal, written or customary, on how a function is to be carried out. As such it includespolicies, strategies, guides, manuals and common practice. This requirement applies toexisting functions and policies, and also to new ones as they are introduced.5.9. In the light of the number of existing areas that require assessment, priority was given toareas identified as failing by the Commission for Racial Equality in the report of theirinvestigation into the Prison Service published in 2003. Establishments were initiallyrequired to perform impact assessments on the ten functions or policies in list A of annex 3,and regular review of these areas remains mandatory.5.10. In addition to the ten mandatory areas for impact assessments, establishments must drawup a list of the other functions and policies that are considered to be relevant to raceequality. This list must be agreed annually by the Area Manager.5.11. The impact assessment list is likely to include the areas in list B of annex 3. This list shouldbe supplemented with any other existing areas that are identified locally using thescreening tool at annex 4.5.12. All new functions and policies that are being introduced, and any proposed changes toexisting policies that are being reviewed, should be assessed for relevance to race equalityusing the screening tool. Where found to be relevant, they should be included in the listand impact assessed, preferably prior to implementation, or where immediateimplementation is necessary, as soon as possible afterwards.5.13 The impact assessment list must be reviewed annually.The Impact Assessment process5.14. Establishments must produce a programme setting out when each of the listed areas willbe impact assessed and how often each area will be reviewed. This programme must beagreed with the Area Manager annually and copied to the Race Equality Action Group.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 145.15. This programme should be based on an assessment of the relevance and priority of theareas on the list. For example, areas where ethnic monitoring data is showing a persistentimbalance in outcomes, or areas where large numbers of complaints are being receivedfrom prisoners of a particular racial group should be prioritised.5.16. Whilst an annual impact assessment programme must be set out and agreed as describedabove, this should not limit Race Equality Action Teams: there should be flexibility withinthe programme to conduct additional impact assessments where problems are identifiedwith existing policies or functions that are not scheduled as part of the programme, andwhere new policies are being introduced.5.17. Impact assessments must be:completed using the template at annexes 4 and 5 (and available on the Forms page of thePrison Service Intranet);submitted to Area Managers in accordance with the agreed programme.No other template must be used. Where establishments have impact assessed areasusing other templates, the new template must be used to replace the existing one when theimpact assessments are reviewed.5.18. Establishments must ensure that:evidence gathered during the impact assessment process is kept for audit purposes;completed impact assessments are discussed and reviewed by Race Equality ActionTeams;action plans from each impact assessment are included in the Race Equality Action Plan;results of impact assessments are published and available for staff, prisoners and visitors.5.19 Area Managers must put in place arrangements for completed impact assessments to bequality assured.Feedback to National Policy Leads5.20. Where establishments or areas identify issues through the impact assessment process thatare the result of national policy, rather than local implementation, they should send theirimpact assessment, highlighting the relevant findings, to the responsible policy lead, andcopy this to REAG.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 15CHAPTER 6 – RACIST INCIDENTSA racist incident is defined as any incident that is perceived to be racist by the victim or anyother person.Establishments must have an effective system for reporting and investigating complaints and racistincidents in which prisoners and staff have confidence.6.1 The induction programme for prisoners must include a structured session on race equality,which covers:Explanation of what constitutes a racist incident;Procedures for submitting a Racist Incident Reporting Form (RIRF), including support forthose who cannot read or write;Explanation of how a racist incident will be investigated;Procedures for protecting the victim, or the person reporting a racist incident.6.2 Information on how to make a complaint must be available in a range of different languagesappropriate to the ethnic make-up of the prisoner/visitor population.6.3 Race Equality induction must be recorded on each prisoner’s F2050A (history sheet).6.4 Racist Incident Reporting Forms (RIRFs) must be readily available throughout theestablishment:Prisoners have free and confidential access to RIRFs;Provision is made to assist prisoners who cannot read and write to make a complaint;Forms (and guidance notes) are available in a range of different languages appropriate tothe prisoner/visitor population;Forms are replenished as necessary.6.5. There must be readily identifiable post boxes for completed RIRFs (formal prisonercomplaint boxes may be used for this purpose):The post box is clearly marked for this purpose and is not under the direct supervision ofstaff;Access to the box is strictly limited to designated staff;Envelopes to safeguard confidentiality are provided with the Racist Incident Report Form;Boxes must be emptied and the contents processed in accordance with the requirements ofthe Complaints Standard.6.6 All racist incidents are recorded on an electronic log. This is printed off and examined bythe leader of the Race Equality Action Team, who is responsible for signing off each RIRF,monthly. The Area Manager is given a copy of the log every six months, and scrutinisesand signs off a random sample of RIRFs (5% or 10 RIRFs whichever is the greater).6.7 All complaints of racism received from any source are:Converted to a RIRF, unless already recorded on one, and a summary of the complaint isrecorded on the form;The form is assigned a log number.6.8 The Race Equality Action Team has agreed specific procedures so that all parties involvedwith a racist incident are safeguarded, including the victim and reporter of the incident.6.9 Investigations must be carried out fairly and appropriately, and in a timely manner, inaccordance with PSO1300.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 166.10. All racist incidents which have been reported from any source must be investigated. In eachcase:A written record must be maintained of the level of investigation selected;All formal investigations are conducted in line with PSO 1300 requirements;The investigator refers findings to the leader of the Race Equality Action Team;The leader of the REAT must complete Section 6 of the RIRF, and record whether anyfurther action is necessary;Any agreed recommended action is implemented;A written record is maintained of the details of the actual investigation and any subsequentaction taken.6.11. The leader of the REAT must ensure that:A complaint is acknowledged within 3 days of it being made;The investigation of the complaint is completed within 28 days of it being made;The complainant is informed of the findings of the investigation within 14 days of completionof the investigation.(These time frames must be complied with, unless an extension is authorised by the leaderof the REAT and the reason recorded on the incident log, and the complainant informed).6.12 The following key actions must be recorded on the electronic log:Findings and outcome of the investigation;The outcome of the investigation has been conveyed to those involved;Target date for completion of the required action;Date when all actions have been completed.6.13 Every year a sample of investigation reports (5% or a minimum of 10 investigations,whichever is the greater) must be examined by an external person or organisation (eg fromthe voluntary and community sector). This is an important way of gaining feedback on theinvestigation process and building confidence in the racist incident reporting system.Individuals conducting these examinations must:Have an understanding of race equality legislation and experience of dealing with raceequality issues;Have an understanding of the Prison Service complaints and investigation processes (itmay be necessary for establishments to provide information and/or training about this);Sign an agreement to maintain appropriate confidentiality, and specifically not to makepublic information about individual cases.A written record must be maintained of the feedback received on the quality of theinvestigations, and any action that will be taken to address the points raised should beincluded in the Race Equality Action Plan.6.14 Establishments must comply with the above standards using the version of the RacistIncident Reporting Form at annex 8, and the electronic log distributed by Race EqualityAction Group. The RIRF is available in 25 languages on the Forms page of the PrisonService Intranet. Guidance on the use of the electronic log is available in the Race EqualityKey Performance Targets Guidance Manual.6.15 The aims of the system are to ensure that:the recording of racist incidents is accurate and standardised;the response to individual incidents is effective and proportionate, thus increasing theIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 17confidence of victims in the system;there is active monitoring of the information by REOs and REATs;there is high quality information available to Area Managers and others on the number andnature of incidents in establishments.Guidance on the use of the RIRF6.16. A racist incident is defined as any incident which is perceived to be racist by the victim orany other person. The definition is included on the form for reference purposes. On eachpage of the form there is a space for a log number to be entered. This refers to the log ofincident reports which the Race Equality Officer must keep and which should be inspectedand discussed at each meeting of the Race Equality Action Team. The Race EqualityOfficer needs to allocate a number to each form and enter the details in the log.6.17. Section 1: the description of the incident can be filled in by anyone who is a victim orwitness to an incident within a prison. This can be a prisoner, any member of staff, anofficial or family visitor or anyone else. The Prison Service‟s commitment to promoting raceequality requires that all staff, uniformed or not, are proactive in addressing racist behaviourand need to be aware of this form as a vehicle for reporting racist incidents. In addition, itshould be made clear to prisoners and visitors that they can also report such behaviour,using this form. Forms need to be widely available if this is to be achieved.6.18. If appropriate, a member of staff can fill the form in on a victim‟s / witness‟ behalf. In thecase of oral reports, letters etc. or of complaints alleged to contain a racial element referredacross by the Complaints clerk, it will often be necessary for the REO to complete a form asappropriate. The intention is not to reduce the ways in which reports can be made butrather to ensure that for every report a complete and consistent record is kept; it isrecognised that some people may be deterred by having to fill in a form themselves.6.19 As with the prisoners‟ formal complaint system, there is evidence to suggest that prisonershave concerns both about reporting incidents in the first place and about whether they willresult in any action. In the case of racist incidents, it makes no difference whether reportsprove to be well-founded or not, whether they result from a misunderstanding or havealready been resolved informally; they must all be reported to the REO. The RIRF providesa convenient way of doing so.6.20 The form has a tear-off slip at Section 2 which must be given to the person reporting theincident (victim or witness) as proof that a report has been submitted. This is intended toincrease confidence in the system and to form part of an audit trail. The tear-off slip mustbe given to the person making the report at the first available opportunity. To ensure thatthe particular incident can be identified, the date should also be noted. Race EqualityAction Teams should decide how best tear-off slips can be given to complainants. In allcases, completed forms are routed to the REO.6.21 Section 3 will be completed by a member of staff, who could be the same person whocompleted Section 1. In many cases the REO will complete this section and in the simplestof cases s/he may conclude that all necessary action has been taken. If this is so it will notbe necessary to enter any further details of action taken in Sections 4 or 5, apart fromconfirmation that feedback has been provided to the original victim/witness.6.22 Section 4 is a full page, and if there are additional pages of information attached thenumber of these should be recorded in the box provided and the log number added.6.23 Section 5 of the form requires information to be provided on any report which has beenwithdrawn. Any decision by a complainant or witness to withdraw the complaint must bethoroughly explored, and any possibility of intimidation needs to be explicitly examined andruled out. In most cases reports are withdrawn at an early stage, before any investigationhas been launched. If this is because the matter has already been resolved by action orIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 18discussions fully described in Section 3, it will be sufficient to state this and give a briefexplanation of the resolution.Verbal accusations of racism by prisoners against members of staff6.24 The use of the term „racist‟ is not in itself racist language. A verbal accusation of racism bya prisoner against a member of staff is therefore unlikely in itself to constitute a racistincident.6.25 If the accusation is accompanied by racial abuse, or any comment about the colour, race,nationality, ethnic origin or religion of the member of staff, this should be considered a racistincident and a RIRF submitted.6.26 In cases where the accusation is not accompanied by racist language, whilst the accusationof racism itself may not constitute a racist incident, the prisoner has stated a perception ofracist conduct by the member of staff, and this issue needs to be addressed.6.27 The circumstances in which such accusations are made vary widely. Sometimes, wherethey are made in a rushed or heated situation, further dialogue between the member ofstaff and the prisoner will not be possible at that time. Where dialogue is possible (eitherimmediately, or by the staff member seeking out a suitable opportunity shortly afterwards),the member of staff should discuss the reason for the accusation and seek to resolve thematter with the prisoner. Whether such dialogue takes place or not, the member of staffmust inform the prisoner that it is open to him/her to raise the matter via a complaint form ora RIRF.6.28 Whether or not the matter is resolved, and whether or not the prisoner indicates that he/sheintends to submit a complaint, the member of staff must submit a written report of theincident to the REO. This should give details about what led up to the incident, as well asreporting what was said by the prisoner. Such reports will not automatically result in aninvestigation. However, if the prisoner subsequently makes a complaint they will be used toinform the resulting investigation.Making the form available6.29. Copies of the form must be freely available on all wings, in the visits area, the healthcarecentre and at the gate. Prisoners should be able to take a form without the intervention of amember of staff. Race Equality Action Team members may wish to consider holding asmall stock of these forms themselves in case they are approached for help and advice.Members of voluntary and community sector groups may wish to do likewise. Confidentialboxes, with access strictly limited to key members of staff, should be provided. The wingboxes used for Complaints forms, may also be used for the RIRFs. Access to the boxesshould be strictly limited and logged forms should be held in a secure place. Confidence inthe system is seriously undermined if reports are not treated with professional diligence.6.30. All prisoners should be informed of the existence of the racist incident reporting form duringinduction, and information - including on the availability of forms - should also bepermanently displayed on relevant notice boards around the establishment. Race EqualityAction Teams will need to consider how best to inform staff and visitors about the system.In addition Independent Monitoring Boards and any other organisations, including voluntaryand community sector groups, working within establishments will need to be informed of thesystem.6.31 Information, together with copies of the forms, will need to be provided in visitors‟ centres,visits areas and at the gate. Visitors will need to be made aware of the existence of theform. Practical difficulties may arise in notifying visitors of the outcome of their complaint,and visitors submitting forms should be encouraged to provide their contact details.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 19CHAPTER 7 – COMMUNITY ENGAGEMENT7.1 The legal obligation for establishments to consult local communities about their policies andfunctions and their impact on people of different racial groups is set out in chapters 2 and 5.There is a related need to communicate widely in promoting our work in order to encouragegood relations between people of all racial groups.7.2 This is particularly important with regard to groups that have historically beendisproportionately represented in the criminal justice system, such as black and minorityethnic people and Gypsies and Travellers. This chapter sets out the way in whichestablishments should go about engaging with these communities.7.3. Some of the other benefits of effective community engagement are:Identification of the different communities that exist in the area of the establishment;Partnership working with other agencies;Involvement in events outside of the prison;External assistance in impact assessments, giving us a credible community perspective;Community groups working within the prison to raise awareness of relevant issues or toprovide services that are otherwise unavailable;External monitoring and scrutiny of the work of the establishment resulting in increasedtrust and confidence of local communities;Recruitment of a more diverse workforce that reflects the local community.Establishments must have a Community Engagement Strategy that sets out how they willcommunicate and consult with the local community on race equality issues.7.4. The strategy must reflect the needs of the prisoner population and the situation in the localarea. It should be appropriately linked to the establishment‟s more general work with thevoluntary and community sector.7.5 The strategy must set out how the establishment will work towards the following high-levelobjectives:Building the trust and confidence of local BME and other minority communities;Consulting meaningfully on policies and functions and their impact on people of differentracial groups;Increasing mutual understanding between the establishment and local BME and otherminority communities.7.6 The strategy must include a statement of the business requirements of the establishment interms of the above high-level objectives.7.7 In formulating or revising the strategy, establishments must undertake a mapping exerciseof existing community engagement work. A database of existing links must be producedsetting out:Name and contact details of partner organisation;Contact point within the establishment;Nature of partner organisation;Purpose of contact / joint working;Benefits to establishment;Funding / benefits provided to partner organisation;Nature of contact / joint working;Details and dates of contact;Evaluation of contact to date;Plans for future contact.This must be revised annually.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 207.8. The Community Engagement Strategy must identify any gaps between this existingprovision and the establishment’s business requirement and include an action plan forclosing these gaps. It must include measures that will be taken to develop capacity involuntary and community sector groups and to provide suitable induction, training andsupport for them to function in the prison environment. Action points deriving from theCommunity Engagement Strategy must be included in the establishment’s Race EqualityAction Plan.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 21CHAPTER 8 – TRAINING8.1 The Prison Service is committed to integrating race equality and diversity training into allareas of staff development and skills training.8.2 Race equality and diversity issues have therefore been incorporated into the PrisonService‟s general training provision. All courses, from initial training for prison officers toleadership and management development programmes, now include race and diversityelements.8.3 A structured training programme – the Ionann diversity training package - has beenproduced and should be used by establishments to deliver local staff training in raceequality and diversity. This may be supplemented with local material agreed by the RaceEquality Action Team.8.4 A new training course on Managing and Promoting Race Equality in Prisons, suitable formembers of establishment Race Equality Action Teams has been devised by REAG. Thishas been successfully piloted in a number of establishments. Training for Area trainers hasbeen arranged, and a programme for local delivery will be agreed with Area Managers.8.5 A revised training programme to support those taking on the new Race Equality Officer rolehas been devised and piloted by REAG. This will be delivered by REAG.8.6 The revised training programme for REOs includes information that will allow REOs todeliver a training course to prisoners who take on the role of representatives on REATs.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 22CHAPTER 9 – COMMUNICATIONS9.1 Communications with staff, prisoners and visitors are important in promoting good racerelations and in ensuring that there is appropriate consultation as part of the impactassessment process.9.2 Establishments must have a Race Equality Communication Strategy (which may be part ofthe establishment’s broader communication strategy) that sets out how they willcommunicate and consult with staff, prisoners and visitors. The strategy must be evaluatedand reviewed annually.9.3 The strategy must include arrangements for:Displaying the Race Equality Policy Statement;The race equality element of prisoner induction;The publication of this PSO;Sharing information about the membership and function of the Race Equality Action Team,including the identities and photographs of the REO and the leader of the REAT;Sharing information about the complaints process, including procedures for protectingvictims / complainants;Publication of management information on race equality, including ethnic monitoring data,MQPL data and visitor survey results;Publication of completed Race Equality Impact Assessments;Publication of the establishment Race Equality Action Plan, quarterly reports on progress,and the formal Annual Report;Sharing relevant information with foreign national prisoners;Sharing information about the diversity of faiths and cultures represented in the prisonpopulation and on the chaplaincy team;Ensuring that all information is available in appropriate languages and formats.9.4. The strategy must set out the way in which the establishment will consult with staff,prisoners and visitors over race equality issues, including impact assessments, and inparticular the arrangements for involving black and minority ethnic staff, prisoners andvisitors in such consultation. It may involve measures to equip staff, prisoners and visitorsto understand the issues involved in sufficient depth to be able to contribute meaningfully tothe consultation process.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 23CHAPTER 10 – MANAGEMENT OF RACE EQUALITY ABOVE ESTABLISHMENT LEVEL10.1 The Prison Service publishes a Race Equality Scheme, an associate scheme of the HomeOffice Race Equality Scheme, setting out the way in which it seeks to comply with theRR(A)A 2000. This document is published every three years and an update on progress ispublished annually.National Level10.2 Overall responsibility for the management of race equality rests with the Director Generaland the Prison Service Management Board. The Race and Equalities Advisor providesadvice to the Director General and the PSMB on the general direction and progress on raceequality. The PSMB holds a quarterly meeting specifically focused on the management ofrace equality, at which progress on the Prison Service Race Equality Action Plan ismonitored.10.3 The Race Equality Programme Management Board is chaired by the Director of Financeand meets every six weeks to oversee progress on the Race Equality Action Plan and theprojects derived from it.Area Level10.4 Area Managers oversee the management of race equality by Governors and SeniorManagement Teams in establishments, receiving quarterly reports on progress on the RaceEquality Action Plan. They use this, together with Key Performance Target and QuarterlyQuestionnaire data, to hold Governors to account for their performance in this area.Race Equality Action Group10.5 REAG takes the lead on race equality policy for the Prison Service and aims to:maintain the focus on race and the Race Equality Action Plan;provide practical assistance and advice to establishments and to policy leads;develop links with communities.10.6 REAG has policy responsibility for the following areas:For PrisonersRace Equality IssuesFor Prisoners and StaffRace Relations KPTs and guidance10.7 It is important to note that policy responsibility for all other prisoner diversity issues rests inthe National Offender Management Service (NOMS) in the Offender Policy and Rights Unit.The NOMS Chaplaincy holds responsibility for all religion and belief issues for prisoners.Policy responsibility for race and diversity issues for staff is held by Personnel ManagementGroup.10.8 REAG consists of four teams:The Programmes and Communication Team – develops and administers the PrisonService Race Equality Action Plan, manages the business support needs of the Group,handles all briefing requests, and has responsibility for the Group‟s communicationsstrategy;Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 24The Race Issues Team – responsible for race equality policy, the aim of which is to achievecompliance with the Race Relations (Amendment) Act 2000. Develops and maintains thePrison Service Race Equality Scheme (RES) and ensures appropriate links with theoverarching Home Office RES and the related work of the NOMS diversity strategy;The Service Delivery and Implementation Team – consists of members of Race EqualityAction Group and operational staff on secondment. Assists establishments with theimplementation of Prison Service policy and compliance with RR(A)A. Responsibility fordiversity-related training. Manages the REAG helpdesk (see below);The Community Links Team - works with external organisations (voluntary and communitysector / business / local government / faith groups / Race Equality Councils etc) oncommunity engagement that will assist establishments in meeting their obligations underthe RR(A)A and enhance the involvement of external groups in the management of raceequality within establishments.10.9 The REAG Helpdesk can be used by any member of staff as a first point of enquiry inconnection with the work of the Group. The Helpdesk can be contacted via telephone or e-mail. All enquiries will receive a response within 48 hours. Contact details are as follows:Helpdesk telephone: 020 7217 2521Helpdesk e-mail: reag@hmps.gsi.gov.ukIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 25RACE EQUALITY ACTION TEAMSTATUSLEADERMEMBERSHIPSub-group of SMTGovernor / Deputy GovernorDiversity ManagerRace Equality OfficerForeign National Prisoner Co-ordinatorHeads of FunctionCo-ordinating ChaplainEducation providerHealthcare providerPrisoner race equality representativesVoluntary and Community Sector representativeIMB observerANNEX 1PURPOSE a) To ensure compliance with PSO 2800b) To provide a clear positive lead on the operational management ofrace equalityc) To manage the Race Equality Action Pland) To report to the SMT quarterlyAIMS1. To ensure that all staff are aware of their responsibilities withregard to race equality2. To ensure compliance with all relevant Prison Service Instructions,Orders and Standards3. To oversee the handling of racist incident report forms andrelevant complaints.4. To manage monitoring data, including areas covered by KPTs5. To collate and disseminate good practice from both the widerPrison Service and external organisations6. To ensure staff and prisoners are appropriately trained in raceequality issues7. To promote race equality and to eliminate unnecessarydiscrimination within the establishment8. To support the work of the Race Equality OfficerMEETINGSAGENDAMonthlyItems to be submitted 1 week prior to the meeting dateWHERE AND WHENMINUTESCirculated to all members within one weekIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 26PRISON SERVICE JOB SPECIFICATION (PSJS)ANNEX 2Establishment or HQ Group/Unit:PLEASE READ „PRISON SERVICE JOB SPECIFICATION GUIDANCE NOTES‟ BEFOREWRITINGJOB TITLEJOB PURPOSE(Refer to PrisonService goals)Race Equality OfficerTo take the lead role in the establishments work to complywith the legal duty to eliminate unlawful discrimination;promote equality of opportunity and promote good relationsbetween different racial groups.ACCOUNTABILITY(use solid lines for line management accountability; dotted lines for other accountabilities)Governor|REAT Leader|Race Equality OfficerDate PSJSwrittenAuthor (name,job title, inblock capitalsHer Majesty’s Prison Service:Serves the public by keeping in custody those committed by the courts.Out duty is to look after them with humanityandhelp them lead law-abiding and useful lives in custody and on releaseTHE PRISON SERVICEIS AN EQUALOPPORTUNITY EMPLOYERPRISON SERVICE GOALS1 Keep prisoners in custody2 Order, control, discipline, safety3 Decent conditions and health care4 Positive regime5 Preparation for releasePRISON SERVICE VALUES1 Integrity2 Commitment by and to staff3 Care for prisoners4 Equality of opportunity5 Innovation and improvementIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 276 Maximum efficiencyDUTIES/TASKS AND PERFORMANCE REQUIRED(Link duties/tasks by category to business plans and Prison Service goals)CATEGORYDUTIES/TASKS AND PERFORMANCE REQUIREDTo oversee and coordinate work on the establishment Race Equality Action PlanEnsure monthly monitoring figures are collated and processed.To ensure all racist incidents are recorded and are dealt with via internal investigationor referral to CRE or Police.To ensure that all prisoners receive Induction Training in Race Relations.To ensure compliance with PSO 2800.To coordinate the completion of Race Equality Impact Assessments.To work with the Voluntary and Community Sector Co-ordinator on managing theCommunity Engagement StrategyTo manage the Race Equality Communication StrategyTo oversee the work of the Assistant Race Equality OfficersTo ensure all new and present staff receive Race Relations training as set down in PSO2800.To organise and assist in the organisation of any diversity promotion events.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 28To attend and participate in any Area meetings as required.To contribute to the ongoing promotion of race equality.To act as a central source of information on relevant legislation, instructions, theservice’s policies and to keep as fully informed as possible about the minority ethnicgroups from whom individuals in custody may be drawn.To make him/herself known and available to staff and prisoners as a source ofinformation and advice so that they may understand and implement the service’spolicies.To advise and work with the establishment’s Race Equality Action Team (REAT) toachieve its objectives.To assist in providing local diversity training, promoting staff and prisoner awarenesson issues relating to diversity.To bring actual and/or potential problems to the attention of the Chair of the REATand/or Governor.To assist in the internal audit of race relations and assist in the preparation of anyknown visit by HMCIP.To keep informed about the relevant laws, policies and guidelines and about otherdevelopments and good practice within the diversity field.To investigate and/or advise in specific investigations where alleged incidents ofbullying, harassment and/or discrimination may have taken place in either this or anyother establishment as instructed.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 29COMPETENCIES REQUIRED(Undertake a profiling exercise for the job and identify key performance indicators from the CoreCompetence Framework)CCF TITLERehabilitationOrientationKEY PERFORMANCE INDICATORSActively supports prisoners rights and choices within the systemDemonstrates fairness by personal examplesChallenges behaviour which may be seen as antisocialOffers guidance and counselling to promote prisoners self esteem and behaviourUpholds prisoners’ access to family, friends and their communityPlanningReviewingCollects and appraises informationSelects all relevant informationAssimilates new and previous informationMakes plans appropriate to the situationCan stand back and take a longer viewGenerates different optionsTeam PlayingNetworkingDemonstrates support and care for all colleaguesBe aware of impact of own behaviour of othersAct always to represent the service wellAddresses issues in a positive mannerChallenges negative behaviourDevelop networks to learn form othersActively upholds equality of opportunityActively rejects any form of discriminatory practiceLeadership andDecision MakingInspires confidence and loyaltyConfronts difficult issues openlyRepresents the organisation both within and outside the serviceMakes judgements which carry convictionCommunicationSkillsOral:WrittenMakes effective presentations.Conducts interviews wellLeads discussions effectivelyWrites with accuracy, brevity and clarityPresents information in a manner appropriate to thereceivers.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 30Annex 3List AMANDATORY AREAS FOR IMPACT ASSESSMENTAccess to religionAdjudicationsAllocation to workCanteenCateringComplaintsGood order or disciplineIncentives and earned privilegesRacist incident reportingUse of forceList BSUGGESTED AREAS FOR IMPACT ASSESSMENTAccess to educationAccess to offending behaviour programmesAllocationCategorisationCell Sharing Risk AssessmentsCommunicationsDrug strategyHome Detention CurfewInductionLegal services and bailLifer proceduresParole proceduresPhysical EducationReceptionResettlementRelease on Temporary LicenceSecuritySegregationSentence ManagementSuicide and Self HarmViolence ReductionVisitsIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 31RACE EQUALITY IMPACT ASSESSMENTSANNEX 4The purpose of this template is to help establishments determine whether functions, policies or practices relatingto service delivery are relevant to race equality and to give guidance on how to conduct full impact assessmentsif it is clear that the function, policy or practice is relevant to race equality.Link To Race Equality Impact Assessments templateSECTION 1Initial screeningThe first stage of conducting a Race Equality Impact Assessment is to screen the function, policy or practice toassess it’s relevance to race equality 1 . This will indicate whether a full impact assessment is required.This first section is required if you are assessing a local function, policy or practice not included in the list offunctions, policies or practices in Annex 3 or if you are making amendments to existing local functions, policiesor practices, or if you are issuing new instructions locally or devising new local policies.Initial Screening template1. Aims and PurposeDescribe the aims and purpose of the function, policy or practice2. ImpactUse this space to describe what impact the function, policy or practice has or, in the case of revisions/ newinstructions, will have on staff, prisoners, visitors or other1 Relevance to Race Equality – For the purposes of the Race Relations (Amendment) Act, „relevance‟ means „having implications for thegeneral duty (to eliminate unlawful discrimination; promote equality of opportunity and promote good relations between different racialgroups). Any function, policy or practice that involves the public (in the Prison Service‟s case this will mainly be in relation to prisoners),including staff, or has consequences for them should be assessed as being relevant to the general duty. Further guidance can be obtainedon the Commission for Racial Equality‟s website: www.cre.gov.uk.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 323. In the case of reviews of existing functions, policies or practices or revisions to existing ones, state whetherthis has come to attention in the past as having a relevance to race equalityUse this space to record your sources of evidence. For example: Was it raised as an issue in the CREFormal Investigation?Have HMCIP/ IMB raised it as an issue?Has it been raised as an issue by prisoners/ visitors/ staff/ others either in consultation forums or atREMT meetings in the past?Have there been complaints/ racist incidents raised about this issue?Has it been raised as an issue through any other sources?If you need any help with this section, please ring the REAG helpline on 020 7217 2521.4. In the case of a new local function, policy or practice or revisions to existing ones, state whether the newprocedures/ revisions themselves could have a differential impact on staff, prisoners or visitors of differentracial groupsFor example:A requirement for all staff to swear on the Bible could have a differential impact on staff from non-Christian faiths.A requirement for all prisoners to submit complaints in English would have a differential impact onforeign nationals.A requirement for all visitors to give a permanent address when booking visits would have adifferential impact on gypsies and travellers as they may not be able to comply with this.5. In this section you need to decide whether the function, policy or practice, or the revisions being proposed,allow staff to exercise discretion in the way it is implemented and whether, as a consequence this could lead todifferential treatment of staff/ prisoners/ visitors of different racial groupsPlease tick which applies:Yesthe function, policy or practice does allow staff to exercise discretion in the way it is implemented and thiscould lead to differential treatmentUse this space to record your findings and your reasoningIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 33Nothe function, policy or practice does not allow staff to exercise discretion in the way it is implemented and thereis no possibility of differential treatmentUse this space to record your findingsGuidance on “Discretion”What does “to exercise discretion” mean?The CRE said in the report of their Formal Investigation into the Prison Service:“It is a general rule that where a system contains greater potential for discretion in decision taking by individualmanagers or individual staff, then there is a greater potential for inconsistent and even discriminatory outcomes[for prisoners, visitors or staff], whether intended or not”.They found that prison staff exercised considerable discretion in carrying out their duties and that thisdiscretion was not adequately managed or monitored by prison managements [locally in establishments].Furthermore, this exercise of discretion led to differential treatment of prisoners 2 .They gave a number of helpful examples of where the use of discretion had a detrimental impact on Black andMinority Ethnic prisoners (these are examples. The list is not exhaustive – it is designed to help you thinkabout whether the same applies to the function, policy or practice being considered):Black prisoners appeared to have been more likely to be targeted for “suspicion” drugs testing thanwhite prisoners;Black prisoners more likely to be subject to the disciplinary system;Black prisoners more likely to be on the basic level in Incentives and Earned Privileges Schemes.The following examples are not taken from the CRE Report but are further examples which could affect staffand visitors:Black and minority ethnic staff being more likely to be subjected to the Attendance Managementprocedures than white staff;The assumption that black and minority ethnic visitors to establishments will be visiting a prisonerrather than in a professional capacity. This will, in turn have an affect on how they could be treated oncoming into a prison.On the surface a function, policy or practice can appear to be free of any racial bias but the way it is interpretedcould lead to discrimination in the way that it is applied.You need to ask yourself, therefore, if the function, policy or practice or the system you are putting in placeallows for either managers or staff to apply it in a way that could have a differential impact on any racial group.If that is the case, you must undertake a full impact assessment and you will need to discuss options foraddressing this. Two areas for possible solution are:2 see “Failure Area 5: Control of the use of discretion”; CRE Report; Part 2 published 15 December 2003.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 341. you could think about the way the revision is to be written and the scope for interpretation allowedminimised;2. you could strengthen management checks to ensure the potential for inconsistency is minimised andindividual members of staff are held accountable for the decisions they have taken.These are just two examples of solutions that are available to you, there may more – staff in Race EqualityAction Group will be happy to discuss this in more detail with you.If you have:indicated in section 3 that this function, policy or practice has come to attention in the past as having a relevanceto race quality, orindicated in section 4 that it could have a differential impact on staff, prisoners or visitors of different racialgroups, orindicated in section 5 that it allows staff to exercise discretion in the way it is implemented then this wouldindicate a “High Relevance” to Race Equality and you MUST complete a full impact assessment (see section 2“Full Impact Assessment Template)If you haveindicated in section 3 that this function, policy or practice has NOT come to attention in the past as having arelevance to race quality, orindicated in section 4 that it could NOT have a differential impact on staff, prisoners or visitors of different racialgroups, orindicated in section 5 that it DOES NOT allow staff to exercise discretion in the way it is implementedthen this would indicate a “Low Relevance” to Race Equality and a full impact assessment will not be required.Please circle which one applies in this case:High RelevanceLow RelevanceName of person undertaking this initial screening…………………………………………………………Signed…………………………………………………Date……………………………………………………Ratified by Chair of REATSigned………………………………………………….Date…………………………………………………….Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 35ANNEX 5FULL IMPACT ASSESSMENT TEMPLATE1. Introduction1.1 Title of function, policy or practice (including local practice)1.2 Manager responsible for this function, policy or practice1.3 Department2. Aims and Purpose2.1 Describe the aims and purpose of this function, policy or practiceFor example an IEP Scheme’s aims and purposes would be to provide a fair and consistent method ofencouraging prisoners to adopt and maintain good standards of behaviour whilst ensuring that they addresstheir offending behaviour, and to ensure the scheme is fairly and consistently applied throughout theestablishment.2.2 Describe the desired outcomes of this function, policy or practiceFor example the desired outcomes of an IEP Scheme could be to contribute to a safe and healthy environment,where staff and prisoners treat each other with dignity and respect and to help reduce bullying and promote ahealthy atmosphere within the prison.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 362.3 Having considered the aims, purpose and desired outcomes of this function, policy or practice use thissection to identify any associated functions, policies or practices that you will take into account during thecompletion of this impact assessment.For example it is clear that the Adjudications policy would need to be considered when looking at IEP.3 Target Group3.1 State who the function, policy or practice is aimed at (e.g. prisoners, visitors, staff, contractors)3.2 State whether anyone else is likely to be affected by its implementation4 Management and Monitoring.4.1 In this section describe the management arrangements for this function, policy or practice.Name/ RoleHow is this managed?Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 374.2 In this section describe the monitoring arrangements for this function, policy or practice. Or, in the case of anew function, policy or practice use this section to describe the monitoring arrangements being put in place.Name/ RoleHow is this monitored? Or, How will this be monitored?4.3 Use the space below to analyse results from the latest monitoring. Auditable, evidence must be kept.5 Evidence of the effect of the function, policy or practice. Auditable evidence must be kept.In this section describe the evidence gathered from existing sources which would indicate the level of relevanceto race equality of this function, policy or practice. When considering this, ensure you have considered ALLracial groups and all three strands of the Duty (i.e. eliminating unlawful discrimination; promoting equality ofopportunity and promoting good relations between people of different racial groups)Information can be obtained from various sources, e.g. CRE Report, HMCIP findings, IMB reports, requests andcomplaints/ Racist Incident Reporting Forms/ grievances, audit reports, local surveys, internal monitoring (seesection 4), meetings, MQPL surveys, previous research, through consultation with prisoners and externalstakeholders (see section 6), or from other sources.5.1SourceCRE ReportHMCIP FindingsIMB ReportsAudit reportsLocal surveysMeetingsMQPL surveysPrevious researchOther sourcesEvidenceIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 385.2 Use the space below to describe any evidence from these sources that suggests thatthere are concerns about any other diversity strands (such as gender, sexual orientation, age,disability, religion or faith).6 Consultation. Auditable, evidence must be kept.6.1 Use this section to list your key stakeholders.Stakeholders – those who are either directly affected by the function, policy or practice or those external bodieswith an interest in the impact of prison service policies (these would normally include those listed in section 3 ofthis template).6.2 Use this section to record the methods of consultation undertaken and issues arising.A key element of the impact assessment process is consultation with your key stakeholders. It is important torecord who you have consulted with and state what issues have arisen as a result.Using the methods described in Annex 5 could help to determine whether certain facilities or services are usedby people of particular racial groups; what people think of the policy and/ or facilities and services on offer; andwhether they are being provided fairly.Consultation Date Issues arising7 Key issues of concern to be considered in all impact assessmentsPrisoner confidence and the use of staff discretion (see point 6 of section 1 “InitialScreening” for definition of “discretion”) have been identified as key issues arisingfrom the impact assessment process. This section must be used to consider therelevance of these issues to this particular impact assessment.IssuePrisoner confidenceUse of discretionDiscussionIndicate how you have ensured/ will ensure prisoner confidencein the function, policy or practice.Indicate whether the function, policy or practice allowsstaff to exercise discretion in the way it is implemented,and what safeguards are being put in place to minimisethe impact on staff, prisoners or visitors of different racialgroups? (For example, are further management checksrequired at a local, area or national level?)Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 398 ConclusionHaving considered the evidence gathered in sections 4, 5 and 6 use the space below to record the key findingsfrom this impact assessment and state what action you will take as a result.A key area to cover here is whether you have considered alternative ways of achieving the aims of the function,policy or practice, especially where you have uncovered the potential for differential impact on people ofdifferent racial groups.State what action will be taken to address any concerns uncovered, giving details of who will undertake themand by when. Actions must be included in establishment’s Business Plan and overarching Race Equality ActionPlan - AuditableConcern Action ResponsibleManagerTarget DateNo further action is required at present. In this case state the rationale behind thisThe concerns identified cannot be addressed because other considerations (such as security) are paramount. Statewhat these considerations are.9. Record of ReviewState how often this function, policy or practice will be reviewed. Must also be in establishment’s action plan.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 40State who will be responsible for the review10. Publishing the Results of the Impact AssessmentState how you will publish the results of the impact assessment (e.g. through the prison’s annual report) andwhen this will happen.Signed (Chair of REAT)Signed (Manager responsible for function)NameDateNameDateIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 41CONSULTATIONIndividuals or groups for establishments to consult may include:ANNEX 6Prisoners - prisoners are directly affected by the organisation's functions, policies and practices and mustbe consulted. This can be achieved via surveys, focus groups etc.Staff - staff are directly affected by the organisation's functions, policies and practices and must beconsulted. The primary avenue of consultation is with the Trade Unions (who also have certainlegislative rights), and this consultation should be detailed, timely and meaningful. Additionalconsultation with staff can also take place through surveys, focus groups, staff meetings etc but thisshould never replace direct consultation with the Trade Unions.Other establishments - Area REO meetings are a good platform for REOs to share information abouteffective external links that have been made and how these have been made.Race Equality Councils (RECs) - RECs have detailed legal and practical knowledge of race equality.All public authorities - e.g. police, local hospitals, local councils, courts etc. All public authoritiesundertake work in relation to their compliance to the RR (A) A 2000. Establishments and theseauthorities can work together to share good practice.Criminal Justice Consultative Forums - all establishments/areas have one and contacts available on theseforums may be useful.Embassies - establishments holding large numbers of foreign national prisoners may benefit fromguidance and advice provided by embassy officials.Local places of worship - e.g. churches, temples, mosques etc.organised links with families and the local community.These places have effective andVoluntary Organisations - it is not a requirement for voluntary organisations to register with a particularbody and proactive efforts must be made to find out what organisations are available in the local area.This can be done by getting in touch with the local council, reading local newspapers, asking the localpress if they have a list of recommended contacts, etc.The National Council for Voluntary Organisations (NCVO) may be able to give you a list oforganisations that are registered with them for your area. Please note this is not a consolidated list andnot all the contacts will have relevant race equality skills. NCVO can be contacted at 8 All Saints Street,London N1 9RL 020 7713 6161.Local businesses - shops, companies, etc may have effective policies on managing race equality whichcan be shared with the prison.Headquarters - Race Equality Action Group or the relevant policy lead in Prison Service headquarters/National Offender Management Service.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 42Good PracticeWorking with external communities is about working together and helping each other with the delivery ofbusiness.It is important to select community groups who are adequately skilled in race equality matters. PSO 4190 onVoluntary Organisations is a helpful tool on how to make the most of the links that have been made.The purpose of consultationThe purpose of consultation is to consult people from all racial groups to take their views into account whendeveloping various policy options.For reviews conducted at Prison Service Headquarters this would normally take the shape of afunction or policy review. In these cases, ideally, consultation should start at the beginning of anyfunction/ policy review or development; it should not be seen merely as a validation exercise at theend of the process. For establishments, this will usually be about finding out if the way functions,policies and practices have been implemented are having a negative impact, which will includecommon practices not necessarily covered by Prison Service policy. It is, therefore, important for youto establish at an early stage the purpose of the consultation exercise.Examples of questions to ask:When impact assessing functions and activities, or the way a particular function or activity is being carried out,establishments may also wish to consider the following:could the way a function, policy or activity is carried out put some racial groups at a disadvantage?could the way a function, policy or activity is carried out have an adverse impact on relations betweendifferent racial groups?if an adverse impact is indicated, is there some way that it could have been avoided? Could it beconsidered to be unlawful racial discrimination? Can it be justified by the aims and importance of thefunction, policy or activity, or are there other ways in which the same aims can be achieved withoutcausing an adverse impact on some racial groups?could the adverse impact be reduced in some way?is there something about the way the national policy is written that is causing adverse impact locally? Isconsultation necessary with the Prison Service Headquarters/NOMS policy group responsible fordeveloping the policy?Methods of consultationThere are many different ways of consulting other than the usual paper based methods. Someexamples include:consultation meetings;focus groups (see Annex B for guidance on Focus Groups);interviews;Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 43surveys.Whatever method is used, establishments should try to make sure:people’s views are used to shape the decision–making process;the exercise represents the views of those who are likely to be affected by the policy;the consultation method is suitable for both the topic and the groups involved;the exercise is in proportion to the effect that the policy is likely to have;the aim of the consultation is clearly explained;the consultation exercise is timetabled and monitored;the findings of the consultation are published.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 44FOCUS GROUPSAnnex 7The Race Equalities impact assessment process suggests running staff and prisoner focus groups. These areextremely effective ways to obtain a wide range of views on an issue. A well-run session will reveal what isimportant or significant for different groups. The following advice is adapted from Social Research Methods2004 by Alan Bryman.Before running a focus group there are a number of practical issues to consider. How are you going to record thesessions, how many participants will be manageable, how many sessions do you need to obtain a representativesection of the stakeholder groups, how are you going to direct the session and what form is your questioninggoing to take?RecordingIn research focus groups the sessions are usually recorded on tape and transcribed so that the flow of ideas is notdisrupted. However this may have issues for the participants of the focus sessions so you need to either, explainand agree to tape recording, or, have an effective note taker who can summarise the points made and check backwith participants that this is an accurate account of their meaning.Size and amount of sessionsThe best size of groups for this kind of session is 6-10. This allows for some drop outs but ismanageable enough for the note taker and facilitator.How many groups? Needs to be enough to reflect the diversity of age/gender/race etc of staff andprisoners and to get a range of views.Do you need to have different focus sessions for different groups of staff/ prisoners to see if there is variation inviews and interpretation of policies and working practices?You will need to take into account time and resources available and decide on a realisticallymanageable number of sessions. If, after two sessions, the views coming out are repeating andconfirming each other then that would be enough, but if they are different you may need to run more.Role of facilitatorTo stimulate discussion by presenting topics/questions,To guide the discussion back on topic,To encourage expansion of topics with probing questions,To chair the session to allow everyone a chance to speak.QuestionsDo you want to start with a few general questions to stimulate discussion followed by extra, more specific,questions during the session, or do you want to use guiding questions or headings and follow a more structuredpattern with time spent on each topic?The second option helps with comparability between groups.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 45Basic Focus Group EtiquetteFacilitator thanks people for coming, goals of session explained and group introduce themselves. Sayhow long session will be. (Name badges help with note taking and facilitating)Only one person should speak at a timeConsider confidentialityEveryone’s views are importantGive other people a chance to speak, make your point then allow others to discuss itIf you disagree with each other then challenge constructivelyAt end facilitator thanks group for participation, explains how the data will be used and asksparticipants to fill in forms with basic information about themselves for monitoring purposes.Checklist for facilitatorHave you thought of how to stop the session being taken over by the more vocal participants?Is your language in the questions/topics clear?Have your questions been designed to create group discussion?Have you tested your recording equipment if using tapes?Have you thought how you will deal with silences?Do you have a strategy for dealing with the discussion if it goes off at a tangent?Have you thought about how much you want to intervene in the discussion?Do you want to sit back and let it flow naturally or do you need to be more directive?Do you want to use flip charts to write the topics onIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 46Annex 8RACIST INCIDENT REPORTING FORMThe attached form is being placed on the Intranet to facilitate easier access for those who donot access the written word for any reason e.g. dyslexia and sight impairment, who wish toreport a racist incident. Consideration needs to be given to offering the form in alternativeformats (e.g. large print) to facilitate access, although the actual wording etc. should not bechanged.PLEASE NOTE, PLACING THIS FORM ON THE INTRANET DOES NOT SUPERSEDE YOUROBLIGATION TO PROVIDE SUFFICIENT HARD COPIES FOR USE BY PRISONERS, VISITORS &STAFF.If you have any queries regarding the completion of this form, please contact the Race &Equalities Action Group Helpline on 020 7217 2521.The RIRF is available in 25 languages on the Forms page of the Prison Service Intranet.Click here for multi-language Racist Incident Reporting FormIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 47Annex 9Community Engagement Evaluation TemplateConduct an evaluation exercise of community engagement happening withinthe prison to establish an overall and in-depth picture of what is taking placewithin an establishment. A local database of this information gathered mustbe developed, maintained and updated and made available to those workingon community engagement within the prison. When undertaking this exercisethe following should be considered:1. Contact details for OrganisationThese details must be kept up to date.By the nature of the their, work voluntary and community sector groups areprone to change not only in personnel but also in the scope or remit ofwork/project that they are working on due to funding criteria andstipulations.2. Background Summary of OrganisationNeeds to include information about what the group does or what their remitis.If the group have a business or project plan which provides backgroundinformation on them information can be taken from thisThe information contained in this part of the evaluation allows internal andexternal parties to have more information as to the work the groupundertakes and in turn raises awareness of the group and its aims andobjectives.Is there a history of working with BME offenders or understanding theirspecific issues?3. Beneficiaries (who benefits) from work/aims and objectives oforganisationsNeed to identify who is benefiting from the work of the group.What sort of benefits are being gained by the beneficiaries and to theprison overall.Are BME prisoners benefiting from this project and if not will need to askwhy not?4. Who established link with prison and in what capacity?Many groups coming into the prison to support or deliver work/projects have been established for manyyears which may indicate that you need to revisit whether the work they do now is still needed, relevantor needs to be reviewed.Many groups are brought in to deliver and support one area of work and the remit grows over time.Again you will need to revisit in what capacity they deliver now.5. How is the group funded (cost implications to prisons/resourcesrequired)?Need to establish how the group is funded presently to do their work and how much exactly it takes tofund the work/project.Need to ascertain that if there is not a financial cost to deliver the service that there may be other types ofIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 48cost such as travel, stationary, IT, staffing costs etc. that need to be consideredIf current stream of funding ceased or funding was needed to meet costs of a project that had notpreviously required funding what would these cost implications be to the prison.Does the group have a business case with projected costings and an annual report(s) with budget sheetscontaining actual costings which could inform the prison about the cost implication required to run sucha project.6. Level of engagement/contact/inputImportant to ascertain the level of the engagement that is taking placeIs the contact with the group frequent and structure into the work of the prison or is it less formalised andtherefore less frequent?How much time is inputted by the external group and what level of that input is with BME prisoners7. Evaluation of the engagement/service provisionEvaluation of a project or area of work provided by an external group should be undertaken to ensurethat the service provision is beneficial to the prison and to the target beneficiaries.In order to evaluate the work it is important to establish the benefits thegroup brings to the prison in terms of work/project outcomes.Is there specific benefit brought to BME offenders by this particular project.Ask groups whether they have undertaken their own evaluation and if sowho has done it. It is in their best interest to ensure that it has been doneexternally in order to maintain credibility and impartiality.It may be useful to see if there are any reports published by otheroverseeing bodies/funders etc. An example might be a report from theAdult Learning Inspectorate regarding an educational project which isbeing delivered in the community but also extends to a prison setting.Talk to staff and prisoners about their own contact/experience of thegroup‟s work.Each establishment may wish to undertake their own evaluation. Byundertaking this exercise a prison is able to assess the benefit of thisgroup‟s work to date and whether it provides the prison itself with anyvalue or should be reviewed.8. Future plans to sustain/continue engagementWhat future plans have been made to continue the engagement/work after any external funding streamshas ended?If engagament/project has been funded internally by the prison what plans are in place to sustain thefunding?If funding is not to continue from either source then how will the work continue?If the engagement/project needs to be reviewed what steps will the prison take to ensure that currentbeneficiaries are not negatively impacted?Are there any other project/work that can be developed to support BME offenders?9. How does the engagement benefit the community?Is the arrangement seen as a reciprocal one? Is the community group benefiting from this arrangementand if so (see below)Is the prison supporting the work of community groups externally from the prison?Is the prison getting involved with working with the community externally ie providing space for events,extending use of its facilities (ie gym, training suite, meeting rooms, external grounds, IT) staff expertiseand/or knowledge through skill swaps etc.Open up channels for future funding ie identifying the prison as a beneficiary of their work by workingin partnershipWhat ways do BME groups benefit from this arrangement?.10. Identify what consultation/external input or scrutiny functionIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 49external groups provideHave community groups contributed to the impact assessment process?If so in what capacity?Are external groups used to scrutinise the work of the prison on a day to day basis?Do BME groups/organisation sit on the REAT or any other meeting within the prison that affects BME?11. External meetings and forum attendedA list of external meetings and forums including all meetings attended at a strategic and practitionerlevel should be collated.Are any meetings specifically BME focused?Do the other meetings provide a forum to discuss issues relating to BME communities and/or offenders?Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 50Annex 10Community Engagement Strategy TemplateOnce the information above has been gathered and evaluated then acommunity engagement strategy should be developed which identifies anygaps between this existing provision and the establishment‟s businessrequirement and include an action plan for closing these gaps. The templateprovides you with information that can be included in the strategy:1. Why does the prison need a Community Engagement Strategy?Duty under the Race Relations Amendment (2000) Act.specifically lookingat the general and specific dutiesResponse to Mapping/Evaluation Exercise findingsWhat exists and what provision it provides.What gaps are there in our current service provision for BME offenders?2. Statement of the business requirements of the establishment in termsof the high-level objectivesEach establishment needs to decide what they need to do to meet theseobjectives ie what resources are required, what types of relationships needto formed with these groups, if gaps in meeting these needs how can theybe filled and if there are no BME groups specifically doing this work isthere scope in assisting in capacity building BME groups who are alreadyworking in the community to support offenders.3. What does Community Engagement mean to this prison?By having this strategy in place what will this enable the prison to do?4. What ways does the prison already engage?If engagement with BME groups has existed then this needs to beincluded.5. Gaps in service identified through the evaluation process?What gaps in service provision exist and in which way can these gaps bemeet?6. What ways has it identified that it can engage in the future? -Methods of engaging?Impact Assessments - consultationGoing out into the community – attending meetings/forums/conferencesHolding focus groups to address specific issues relating to prisonsFilling gaps in service provision – partnership working7. Action PlanIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 51Need to have an action plan form a response to identified gaps in servicesNext steps to be set out with clear objective, outcomes, resourcesrequired, leads, time framesEnsuring actions taken with the community are promoted by the prison andthat external mechanisms within the community or developed by thecommunity are used to promote the work also.Ensuring that the work undertaken by the community in partnership withthe prison is promoted widely within the individual establishment, withREAG and across the service to use as best practice in the future.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 52RACE EQUALITY IMPACT ASSESSMENTSTO BE COMPLETED IN ACCORDANCE WITH CHAPTER 5 ANDANNEXES 4, 5, 6 AND 7 OF PSO 2800The purpose of this template is to help establishments determine whetherfunctions, policies or practices relating to service delivery are relevant to raceequality and to give guidance on how to conduct full impact assessments if itis clear that the function, policy or practice is relevant to race equality.SECTION 1Initial screeningThe first stage of conducting a Race Equality Impact Assessment is to screenthe function, policy or practice to assess it‟s relevance to race equality 3 . Thiswill indicate whether a full impact assessment is required.This first section is required if you are assessing a local function, policy orpractice not included in the list of functions, policies or practices in Annex 3 orif you are making amendments to existing local functions, policies orpractices, or if you are issuing new instructions locally or devising new localpolicies.Initial Screening template1. Aims and Purpose2. Impact. Use this space to describe what impact the function,policy or practice has or, in the case of revisions/ new instructions,will have on staff, prisoners, visitors or others.3 Relevance to Race Equality – For the purposes of the Race Relations (Amendment) Act, „relevance‟ means „having implications forthe general duty (to eliminate unlawful discrimination; promote equality of opportunity and promote good relations between differentracial groups). Any function, policy or practice that involves the public (in the Prison Service‟s case this will mainly be in relation toprisoners), including staff, or has consequences for them should be assessed as being relevant to the general duty. Further guidancecan be obtained on the Commission for Racial Equality‟s website: www.cre.gov.uk.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 533. In the case of reviews of existing functions, policies or practicesor revisions to existing ones, state whether this has come toattention in the past as having a relevance to race equalityIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 544. In the case of a new local function, policy or practice or revisionsto existing ones, state whether the new procedures/ revisionsthemselves could have a differential impact on staff, prisoners orvisitors of different racial groups5. In this section you need to decide whether the function, policy orpractice, or the revisions being proposed, allow staff to exercisediscretion in the way it is implemented and whether, as aconsequence this could lead to differential treatment of staff,prisoners or visitors of different racial groupsPlease tick which applies:Yesthe function, policy or practice does allow staff to exercisediscretion in the way it is implemented and this could lead todifferential treatmentUse this space to record your findings and your reasoningNothe function, policy or practice does not allow staff to exercisediscretion in the way it is implemented and there is no possibility ofdifferential treatmentUse this space to record your findingsIf you have:indicated in section 3 that this function, policy or practice has come toattention in the past as having a relevance to race quality, orIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 55indicated in section 4 that it could have a differential impact on staff,prisoners or visitors of different racial groups, orindicated in section 5 that it allows staff to exercise discretion in the way it isimplemented then this would indicate a “High Relevance” to Race Equalityand you MUST complete a full impact assessment (see section 2 “Full ImpactAssessment Template)If you haveindicated in section 3 that this function, policy or practice has NOT come toattention in the past as having a relevance to race quality, orindicated in section 4 that it could NOT have a differential impact on staff,prisoners or visitors of different racial groups, or indicated in section 5 that itDOES NOT allow staff to exercise discretion in the way it is implemented thenthis would indicate a “Low Relevance” to Race Equality and a full impactassessment will not be required.Please circle which one applies in this case:High RelevanceLow RelevanceName of person undertaking this initial screening…………………………………………………………Signed…………………………………………………Date……………………………………………………Ratified by Chair of REATSigned………………………………………………….Date…………………………………………………….Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 561. IntroductionFULL IMPACT ASSESSMENT TEMPLATE1.1 Title of function, policy or practice (including local practice)1.2 Manager responsible for this function, policy or practice1.3 Department2. Aims and Purpose2.1 Describe the aims and purpose of this function, policy orpractice2.2 Describe the desired outcomes of this function, policy orpractice2.3 Having considered the aims, purpose and desired outcomes ofIssue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 57this function, policy or practice use this section to identify anyassociated functions, policies or practices that you will take intoaccount during the completion of this impact assessment.3 Target Group3.1 State who the function, policy or practice is aimed at (e.g.prisoners, visitors, staff, contractors)3.2 State whether anyone else is likely to be affected by itsimplementation4 Management and Monitoring.4.1 In this section describe the management arrangements for thisfunction, policy or practice.Name/ RoleHow is this managed?Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 584.2 In this section describe the monitoring arrangements for thisfunction, policy or practice. Or, in the case of a new function, policyor practice use this section to describe the monitoringarrangements being put in place.Name/ RoleHow is this monitored? Or, Howwill this be monitored?4.3 Use the space below to analyse results from the latestmonitoring. Auditable, evidence must be kept.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 595 Evidence of the effect of the function, policy or practice. Auditable, evidencemust be kept.5.1SourceEvidenceCRE ReportHMCIP FindingsIMB ReportsComplaints/ RIRFs/grievancesAudit reportsLocal surveysMeetingsMQPL surveysPrevious researchOther sources5.2 Use the space below to describe any evidence from thesesources that suggests that there are concerns about any otherdiversity strands (such as gender, sexual orientation, age,disability, religion or faith).6 Consultation. Auditable, evidence must be kept.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 606.1 Use this section to list your key stakeholders.6.2 Use this section to record the methods of consultationundertaken and issues arising.Consultation Date Issues arising7 Key issues of concern to be considered in all impact assessmentsPrisoner confidence and the use of staff discretion (see point 6 of section 1“Initial Screening” for definition of “discretion”) have been identified as keyissues arising from the impact assessment process. This section must beused to consider the relevance of these issues to this particular impactassessment.IssuePrisoner confidenceDiscussionUse of discretion8 ConclusionHaving considered the evidence gathered in sections 4, 5 and 6use the space below to record the key findings from this impactassessment and state what action you will take as a result.Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 61State what action will be taken to address any concernsuncovered, giving details of who will undertake them and by when.Actions must be included in establishment‟s Business Plan andoverarching Race Equality Action Plan - AuditableConcern Action ResponsibleManagerTarget DateNo further action is required at present. In this case state therationale behind thisThe concerns identified cannot be addressed because otherconsiderations (such as security) are paramount. State what theseconsiderations are.9. Record of ReviewState how often this function, policy or practice will be reviewed.(must also be in establishment’s action plan).Issue No. 264 issue date 25/09/06

PSO 2800 Annexes – Page 62State who will be responsible for the review10. Publishing the Results of the Impact AssessmentState how you will publish the results of the impact assessment(e.g. through the prison‟s annual report) and when this will happen.Signed (Chair of REAT)Signed (Manager responsiblefor function)NameDateNameDateIssue No. 264 issue date 25/09/06