Back to Equality and Human Rights Impact Assessments (EqHRIA)

Vehicle tracking

Section 1 - Scoping

SEPA fleet vehicle tracking and driver behaviour software

13/03/2025

Beth Fotheringham

Fiona Mactaggart

Data Protection Impact Assessment in progress.

Section 2 - Screening

SEPA intend to reintroduce telematics to their fleet vehicles to gain a better understanding of the journeys taken, where vehicles are located and to be an enabler for better journey planning, once we have sufficient data, to support a reduction in overall business mileage. Telematics will also inform where we need to base our fleet vehicle as we roll out our Workspaces Strategy and to support business delivery and achieve a reduction in overall mileage CO2 emissions to support our ambitions of being a net zero exemplar.

With driving being one of the most dangerous activities employees can undertake at work, we also require a system that supports SEPA to reduce their road risk and will actively encourage employees to make appropriate and timely decisions to change their behaviour on the road as required, to maximise their safety.

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.

I do not believe that this relates to any of SEPA’s Equality Outcomes.

No.

SEPA had vehicle tracking in place until 2023. Tracking was removed due to the high number of vehicle disposals, vehicle replacements and the number of hires SEPA were using. It was also recognised that due to the age of the tracking that was in place at that time, a DPIA had not been carried out, and this would need to be completed prior to introducing a new SEPA fleet tracking system.

Employees who drive SEPA fleet vehicles.

One of the key deliverables of the Fleet Strategy is to have tracking in place to inform where SEPA fleet vehicles need to be located for operational purposes, to improve fleet efficiency and reduce fleet running costs.

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	Neutral	Neutral
Disability	Negative	Neutral	Neutral
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

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.

SEPA will communicate to all employees that tracking will be reinstalled in SEPA fleet vehicles. SEPA fleet should only be used for business use; personal use of fleet is not permitted to ensure we comply with HMRC rules and to meet the requirements of the fleet insurance provision. SEPA will not use data collected for any other purpose other than to:

To identify opportunities to transition to a zero emission fleet.
To maximise the efficiency of the fleet.
To identify the most appropriate base locations for fleet vehicles to maximise efficiency.
To identify where provision of fleet needs to be enhanced/ reduced to meet business demand.
To promote a culture of safe driving in SEPA.
To provide evidence of driver behaviour for our fleet insurer to lower insurance premiums.
To provide evidence of speed / driver behaviour to support any any accident/ incident investigation.
To understand the real time location of vehicles, what vehicles are used at any time and the duration a vehicle has been idle.
Ensure compliance with HMRC rules.
Ensure use is in line with the insurance provision.

Right to respect for private and family.

The tracking software will be used by all employees who use SEPA fleet including hires.

SEPA will engage with Unison ahead of implementation.

Vehicle tracking and driver behaviour software will embed a culture of safe driving in SEPA. The SEPA fleet racking element will enable SEPA to locate fleet to support demand and best support the needs of employees undertaking travel on SEPA’s behalf.

Article 8 – As the telematics will use a GPS signal, the location of SEPA fleet vehicle will be known at all times. For employees who have opted to take a vehicle home, such as the National Monitoring Team, their home location will be shown on any reports. It is optional for all employees who are allocated a van as part of their role to take it home, and employees should be aware that we are required to share the location of where a vehicle is based with our fleet insurer. SEPA will not use the location information of the vehicle for any other purpose other than those already noted.

Article 8 – SEPA will develop a clear policy around the use of data collected from our fleet once a contract has been awarded and will communicate this with employees. A full DPIA will be carried out ahead of implementation also.

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.

Unison will be consulted as part of the implementation and development of the policy.

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 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.

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.

04/06/2026

Section 5 - Sign off

04/06/2025

Yes

Vehicle tracking

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.