Back to Equality and Human Rights Impact Assessments (EqHRIA)

Asset bank

Section 1 - Scoping

Asset Bank SEPA Image Library

19/05/2025

Gary Paton and Lorna Bryce

Clare Noblett

Yes, a DPIA has been completed for the platform.

Section 2 - Screening

We aim to eliminate unlawful discrimination by ensuring that the SEPA Image Library is accessible, where possible, to all colleagues and members of the public who may need to use the platform.

We also want to ensure that the supplier of the platform, Bright Interactive, aligns with our commitment to Equality and Human Rights.

SEPA’s Equality Outcomes 2022-2026

Outcome 1 – We have increased the number of people from currently underrepresented groups in our applicants, our staff and those who progress within the organisation.
Outcome 2 – People with lived experience of inequality, related to a protected characteristic or socioeconomic status, access and use SEPA’s services without barriers.
Outcome 3 – Staff with lived experience of inequality and barriers, and with a wide variety of needs, feel listened to and respected as SEPA meets those needs.
Outcome 4 – We have decreased our gender pay gap and occupational segregation related to gender, disability, and ethnicity.

Outcomes 2, 3 and 4. We want to ensure that all colleagues, regardless of their background or ability, can use the platform. The platform can also be used to showcase and, in turn, foster diversity in the workplace and through our communications.

Main stakeholders are SEPA colleagues, predominantly members of the communications team who are expected to use the platform in their role. Guidance and training is available to all SEPA staff via the intranet and Discover portal. Training must be completed before access is provided.

Secondary stakeholders are potentially adult members of the public that we will direct to a public facing area of the platform. The intention is to use it as a repository of resources to support campaigns and engagement, using the platform to provide approved image and video resources to the public.

Project scope.

2.6

The Equality Act 2010 places a duty on public bodies to prevent discrimination in all aspects of service provision. It provides a clear and positive legal duty to eliminate discrimination and to ensure equality of opportunity and good relations between different groups.

Amongst your group of stakeholders are there any people who belong to the protected characteristic groups listed below who may be impacted, either positively or negatively, or do you believe there is a neutral impact?

Consider the three needs of the general duty for each Protected Characteristic in turn.

Table 1 - Public Sector Equality Duty - Screening tool

	Eliminate discrimination, harassment and victimisation and other conduct prohibited under the Equality Act	Advance equal opportunities between people who have a protected characteristic and those who do not	Foster good relations between people who have a protected characteristic and those who do not
Age	Neutral	Positive	Positive
Disability	Negative	Positive	Positive
Gender reassignment	Neutral	Positive	Positive
Marriage / Civil partnership	Neutral	Positive	Positive
Pregnancy / Maternity	Neutral	Positive	Positive
Race	Neutral	Positive	Positive
Religion / Belief	Neutral	Positive	Positive
Sex	Neutral	Positive	Positive
Sexual orientation	Neutral	Positive	Positive

2.7

Will the policy or practice engage or restrict a right or freedom under the Convention?

If you answer 'Yes' for any of them, go to Section 3.

Human Rights human lives a guide for public authorities.

Table 2 - Human Rights consideration

Human Rights Act Article	Yes	No
Article 2: Right to life		X
Article 3: Prohibition of torture		X
Article 4: Prohibition of slavery and forced labour		X
Article 5: Right to liberty and security		X
Article 6: Right to a fair trial		X
Article 7: No punishment without law		X
Article 8: Right to respect for private and family		X
Article 9: Freedom of thought, conscience, and religion		X
Article 10: Freedom of expression		X
Article 11: Freedom of assembly and association		X
Article 12: Right to marry		X
Article 13: Right to an effective remedy		X
Article 14: Prohibition of discrimination		X
Protocol 1, Article 1: Protection of property		X
Protocol 1, Article 2: Right to education		X
Protocol 1, Article 3: Right to free elections		X

If you answer 'Positive' or 'Neutral' in Table 1 or 'No' in Table 2 for all of the questions you may not need to carry out a full assessment. You should discuss this decision with the senior leader responsible for the work.

Section 3 - Full Assessment

Eliminate unlawful conduct.
Advance equality of opportunity.
Foster good relations.

There should be no impact on SEPA’s ability to comply with the three elements of the Public Sector Equality Duty from the use of the Asset Bank platform.

All protected groups.

Disability – people who may struggle to use computers and smartphones without adaptation or support.

Yes, the Image Library can contribute to positive equality and human rights outcomes.

By ensuring that images are accessible and inclusive, the platform can enhance the representation and visibility of diverse groups.

By including a diverse range of images, the library could foster a more inclusive environment and promote awareness and understanding of different experiences and perspectives.

Additionally, providing accessible and well-tagged images can help individuals with disabilities navigate and utilise the platform effectively, thus promoting equal access to information and resources.

Guidance and training in the use of the Image Library, both to upload and access images, provides an additional opportunity to remind colleagues of SEPA’s commitment to good practice and our accessible communications approach.

This is supported by a clear and consistent approach to consent providing subjects with control over their image use. This has also been subject to a Data Protection Impact Assessment.

Yes, the Image Library can impede positive equality and human rights outcomes if it does not contain images showcasing diversity and inclusion.

The overall accessibility of the Image Library will be significantly reduced if the metadata stored on the platform is inaccurate and users do not store images correctly.

The developers of Asset Bank have built the platform to be compliant with WCAG 2.1 Level AA in all areas and features where possible. Due to the vast configuration options and levels of customisation within the platform, and any like it, meeting this standard is sometimes not possible.

To resolve any accessibility issues surrounding the use of the platform, the Image Library Admin team will work to support colleagues in the use of the platform. Primarily, this is done by ensuring the relevant accessibility metadata tags are in place, including Alt Text descriptions, and assets are easy to find and use in a clear manner. Additionally, the admin team will support colleagues and the public in a timely manner when accessibility issues cannot be resolved in platform.

The team will also develop mitigations as any issues arise with the collection and processing of images and personal data.

The admin team should endeavour, where possible, to collect and store a range of diverse images that foster a more inclusive environment and promote awareness and understanding of different experiences and perspectives.

The Asset Bank Admin Manual is an internal document that outlines the role that the team plays within the organisation.

Accessibility Statement for Asset Bank – Asset Bank Help Centre

Asset Bank and Accessibility – Asset Bank Help Centre

Section 4 - Continuous monitoring and improvement

Option 1: No major change

Your assessment demonstrates that the policy or practice is robust. The evidence shows no potential for:

Less favourable treatment of particular groups, indirect discrimination, victimisation, harassment, and that you have taken all opportunities to advance equality of opportunity and foster good relations; nor
Restriction of Convention rights or freedoms.
The platform is being continually developed with accessibility in mind. The core pages should support reasonable adjustments at this time while future iterations should address existing weaknesses.
Accessibility Statement for Asset Bank – Asset Bank Help Centre
Asset Bank and Accessibility – Asset Bank Help Centre
The library admin team role is designed to support accessibility for all groups and to support the organisation in the use of the tool where possible. This role can be adjusted and best practice developed going forward.

The Equality and Human Rights Impact Assessment is a living document and should be reviewed and updated to ensure you have captured the changes that have been made because of the implementation of your policy or practice. Set a realistic goal for you to check back in with your assessment, to see if things are going the way you expected.

Date for the Equality and Human Rights Impact Assessment review.

07/07/2028

Section 5 - Sign off

11/06/2025

Yes

Asset bank

Section 1 - Scoping

1.1 What is the subject/title of your policy or practice?

1.2 Date Equality and Human Rights Impact Assessment started.

1.3 Name(s) of staff members carrying out the Equality and Human Rights Impact Assessment.

1.4 Name of senior leader signing off Equality and Human Rights Impact Assessment.

1.5 Have you considered which other impact assessments may be required, e.g. Data Protection or Islands Communities Impact?

Section 2 - Screening

2.1 What are the aims of your policy or practice, and how do they relate to equality and human rights?

2.2 Does it relate to any of SEPA’s Equality Outcomes?

2.3 Is it a major policy or practice, significantly affecting how functions are delivered?

2.4 Thinking about the purpose and outcomes of your policy, who are the people who may be impacted i.e., main stakeholders and how do you plan on engaging with them?

2.5 Which sources of information did you use to make this decision?

Section 3 - Full Assessment

3.1 What impact will the application of the policy or practice have on SEPA’s ability to comply with each of the three elements of the Public Sector Equality Duty?

3.2 To which of the protected characteristic groups is the policy or practice relevant?

3.3 Which of the protected characteristic groups and communities might it be helpful to involve in the development of the policy or practice?

3.4 Are there positive equality or human rights outcomes you could expect from the implementation of this policy or practice?

3.5 Are there any negative equality or human rights outcomes that you could expect from the implementation of this policy or practice?

3.6 Consider what actions will you take to eliminate, or limit to the best of your abilities, any negative impact.

3.7 What sources of information did you use? Include any further evidence gathering and external engagement that is required to demonstrate that you are giving ‘due regard’ to the equality duty of eliminating discrimination, promoting equality of opportunity, and fostering good relations.

Section 4 - Continuous monitoring and improvement

4.2 Date for the Equality and Human Rights Impact Assessment review.

Section 5 - Sign off

5.1 Date Equality and Human Rights Impact Assessment reviewed and accepted by Equality and Human Rights officer.

5.2 Confirmation the Senior Leader has reviewed and signed off Equality and Human Rights Impact Assessment.