Back to Equality and Human Rights Impact Assessments (EqHRIA)

Governance, Risk and Compliance System

Section 1 - Scoping

Governance, Risk and Compliance System for the management of risk, performance, audit actions and potentially other governance services in the future.

16/03/2026

Katie Cairnie

Kieron Gallagher, Head of Governance, Risk & Resilience

A Data Protection Impact Assessment has been completed and is awaiting sign off.

An Islands assessment is not necessary as this is a remotely accessed system.

Section 2 - Screening

A Governance, Risk and Compliance system (to manage risk and performance) will bring efficiencies, allowing us to update and track risks and performance measures in real time as well as enabling us to ensure compliance with standards and provide better management information for improved decision-making at all levels of management. It would also allow us to standardise controls across the organisation and potentially link the same mitigation actions, making it easier to update and manage risk across SEPA and allow us to put in place processes for testing the effectiveness of those controls.

The current processes for updating and tracking risk and performance are to use spreadsheets which aren’t as accessible, are restricted to certain people, and have a high level of risk in terms of data corruption, deletion etc. A system will mitigate this, provide wider access to specific information for the people who need it to do their job, and will be able to produce output reports in different formats and in real time.

The new system will be compliant with SEPA’s accessibility requirements.

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.

Outcome 3

The system will meet SEPA accessibility requirements which removes inclusion barriers.

No, it is a different way of collecting, collating and disseminating key information more quickly than the current manual processes.

The key people impacted will be the Corporate Leadership Team, Senior Leaders, Risk Champions and some band B and C managers who own actions.

There will be full training provided before licences are distributed.

It was part of the strategic review of risk management, which took place in 2024-2025.

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	Neutral	Neutral
Disability	Negative	Positive	Positive
Gender reassignment	Neutral	Neutral	Neutral
Marriage / Civil partnership	Neutral	Neutral	Neutral
Pregnancy / Maternity	Neutral	Neutral	Neutral
Race	Neutral	Neutral	Neutral
Religion / Belief	Neutral	Neutral	Neutral
Sex	Neutral	Neutral	Neutral
Sexual orientation	Neutral	Neutral	Neutral

SEPA as a public authority is obliged to ensure that our decisions and actions align with the fundamental rights and freedoms enshrined in the European Convention of Human Rights.

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

Section 3 - Full Assessment

Eliminate unlawful conduct
Advance equality of opportunity
Foster good relations

We are currently going through procurement for a system that will improve risk and performance reporting and information, making it more accessible to those who need it in real time. Removing the need for spreadsheets and a lot of manual information handling and processing. Once the preferred system is in place we can look at how we can use the Public Sector Equality Duty to educate and inform peers about the use of the new system.

Disability

The system is a commercial off the shelf solution (COTS) going through procurement.

WCAG 2.1AA accessibility is a SEPA requirement for all new systems.

No further internal testing required.

No, as the system will be WCAG 2.1AA compliant.

Ensured that system will be WCAG 2.1AA compliant.

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.

GOV.UK digital marketplace, G-cloud lot 13 accessibility filters.

Section 4 - Continuous monitoring and improvement

There are four options, select the one that is appropriate to your findings and provide any supporting information you have for that decision.

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 policy or practice builds in reasonable adjustments where these may be needed. In reaching this conclusion, you should document the reasons why and the evidence used to support your decision.

01/04/2027

Section 5 - Sign off

31/03/2026

Yes

Governance, Risk and Compliance System

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?

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.

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

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?

Section 4 - Continuous monitoring and improvement

4.1 Now you have completed the evidence gathering, this needs to be applied to the policy or practice. Having considered the actual and potential impacts, you can decide what needs to happen next

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.