Strategic Approach to Our Workspaces
Section 1 - Scoping
'Strategic Approach to Our Workspaces' which describes how we will deliver the workspace outcomes in our How We Work vision.
August 2023. Formal approval was delayed due to absence of Head of Workspaces and Environment until August 2024. Content has been updated and refined within the new Equality and human rights impact assessment template.
Setareh Stephan, Fiona Mactaggart & Andy Grierson
Kirsty Paterson
Yes – nothing else required.
Section 2 - Screening
Aims: SEPA’s workspace transformation will enable flexible working, support a net zero organisation, and ensure 24/7 service delivery
Rationale: Due to the pandemic, the way organisations work has changed. SEPA is adapting to these changes and fiscal, net zero, and flexible working targets.
Current Situation: Our current workspaces are underutilised due to more flexible working practices.
Proposed Changes: The Strategic Approach to Our Workspaces involves moving from traditional owned/leased buildings to a more dynamic approach with shared, flexible, and low-emission workspaces.
Implementation: Based on Scottish Government direction and Agency Board approval, we will achieve this by:
• Reducing workspace costs and emissions.
• Determining workspace locations based on national service delivery needs.
• Co-locating with public sector organisations and partners by default, only owning or leasing buildings if necessary
Yes, 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.
Yes, the Strategic Approach to our Workspaces is a strategic framework that significantly affects how functions are delivered.
All SEPA colleagues will be impacted due to potential workspace location changes and new ways of working. Co-location with other organisations will also impact working practices due to information and equipment security needs.
We engaged with colleagues in developing the How We Work vision and held sessions to share the Strategic Approach to Our Workspaces.
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 | Negative | Negative | Negative |
| Disability | Negative | Negative | Negative |
| Gender | Negative | Negative | Negative |
| Marriage / civil partnership | Neutral | Neutral | Neutral |
| Pregnancy / Maternity | Negative | Negative | Negative |
| Race | Neutral | Neutral | Neutral |
| Religion / belief | Negative | Negative | Negative |
| Sex | Neutral | Neutral | Neutral |
| Sexual orientation | Neutral | Neutral | Neutral |
2.7 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.
Will the policy or practice engage or restrict a right or freedom under the Convention?
The impact of the How We Work vision and Strategic Approach to Our Workspaces while intended to be a positive change could potentially have negative impacts on employees’ human rights.
Table 2 - Human Rights consideration
| Human Rights Act Article | Yes | No |
| Article 2: Right to life | No | |
| Article 3: Prohibition of torture | No | |
| Article 4: Prohibition of slavery and forced labour | No | |
| Article 5: Right to liberty and security | No | |
| Article 6: Right to a fair trial | No | |
| Article 7: No punishment without law | No | |
| Article 8: Right to respect for private and family | Yes | |
| Article 9: Freedom of thought, conscience, and religion | No | |
| Article 10: Freedom of expression | No | |
| Article 11: Freedom of assembly and association | No | |
| Article 12: Right to Marry | No | |
| Article 13: Right to an effective remedy | No | |
| Article 14: Prohibition of discrimination | Yes | |
| Protocol 1, Article 1: Protection of property | No | |
| Protocol 1, Article 2: Right to Education | No | |
| Protocol 1, Article 3: Right to free elections | No |
Section 3 - Full Assessment
• Eliminate unlawful conduct
• Advance equality of opportunity
• Foster good relations
The People Strategy and How We Work vision will provide clarity and a framework for employees and managers, supporting equality, opportunity, and good relations.
• Age
• Disability
• Gender Reassignment
• Pregnancy / Maternity
• Religion / Belief
We have consulted with colleagues throughout the development of the How We Work vision and Strategic Approach to Our Workspaces.
Supporting Information and Feedback:
• Workspace surveys in 2021 and 2022 on work location preferences.
• Monthly office occupancy data.
• Feedback on the Hybrid Working Policy in 2022 and 2024.
• Feedback on contractual changes in Edinburgh, Glenrothes, and Arbroath.
• Feedback on office closures and the Regional Hub model.
• Concerns noted from colleagues.
• Pilot of the new way of working in the South East Regional Hub.
• Colleague survey in late 2023.
• UNISON feedback on the How We Work vision, Strategic Approach to our Workspaces, and Regional Hubs.
• Age: Increased flexibility and choice in work location, potentially reducing commuting time for those with caring responsibilities.
• Disability: The option to work from home and/or quiet areas in hubs provides more choice for those with neurodiversity.
• Pregnancy / Maternity: increased flexibility for pregnant and nursing colleagues with hybrid working and choice of workspace.
• Right to Private and Family Life (Article 8, ECHR): increased flexibility for pregnant and nursing colleagues with hybrid working and choice of workspace.
• Age: Potential impact on those with caring responsibilities due to alternative working patterns and travel time to new workspaces.
• Disability: Need for fully accessible workspaces, including wheelchair-user friendly spaces, adjustable workstations, parking for blue badge holders, accessible facilities, and assistive software.
• Gender Reassignment: Need for safe and appropriate toilet and changing facilities for all genders.
• Pregnancy / Maternity: Potential impact due to longer travelling times to new workspaces and the need for quiet rooms, first aid rooms, and a separate fridge for breast milk storage.
• Religion / Belief: Need for quiet rooms for contemplation or multi-faith prayer rooms.
• Right to Private and Family Life (Article 8, ECHR): Potential impact due to increased commute time, stress, and health.
• Right to Non-Discrimination (Article 14, ECHR): Potential for indirect discrimination due to less accessible locations or commutes, and lack of consultation.
• Right to Fair Working Conditions (Article 7, ICESCR): Potential impact due to poorer facilities, less comfortable working spaces, reduced access to amenities, and job security.
• Right to Freedom of Association (Article 11, ECHR): Potential impact due to reduced participation in trade union activities or access to union support.
• Each workspace location will have its own specific Equality and Human Rights Impact Assessment.
• In co-locating with other public sector organisations colleagues will have access to better workspace choice and working environments.
• Commitment to creating inclusive and supportive work environments.
• Increased flexibility and choice in work locations.
• Support for neurodiversity.
• Fully accessible workspaces.
• Support for gender reassignment.
• Quiet rooms and first aid rooms.
• Consultation with colleagues and UNISON.
• European Convention on Human Rights (ECHR).
• Guidance from the Scottish Human Rights Commission.
• Legal duty to consider and mitigate impacts on employees' human rights.
• Workplaces programme: equality impact assessment - summary - gov.scot
Section 4 - Continuous monitoring and improvement
Option 2: Adjust the policy / practice.
This involves taking steps to:
• remove any barriers, to better advance equality or to foster good relations; and
• to minimise any restriction of Convention rights or freedoms.
It may be possible to remove or change the aspect of the policy that creates any negative or unwanted impact. You should describe additional measures which could be taken to reduce or mitigate any potential negative impact.
This Equality and human rights impact assessment has been developed at a strategic level in the context of the Strategic Approach to Our Workspaces. We will undertake a separate Equality Human Rights Impact Assessment for every workspace location/move. We will work to ensure new workspaces can accommodate wherever possible, the additional measures noted above to mitigate any potential negative impact.
The EqHRIA 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.
1st December 2025
Section 5 - Sign off
13/12/2024
Yes
Kirsty Paterson 9th January 2025