Equality and diversity

For further information about anything you read in this section, please contact Emdad Haque, Senior Equality, Diversity and Inclusion Manager at emdad.haque@nhs.net

Our Equality, Diversity and Human Rights commitments

North Central London CCG is committed to commissioning the very best care for the diverse population we serve, recognising that services need to be designed with equality, diversity and human rights at the core of business and decision-making.

We are committed to fulfilling our equality duties and obligations to reduce avoidable health inequalities in all aspects of our role and functions. The values underpinning equality, diversity and human rights are central to our policy making, service planning, employment practices and commissioning.

For our staff, we aim to create a working culture that recognises, respects and values differences for the mutual benefit of the organisation and the individual.

The Equality Act 2010 legally protects people from discrimination in the workplace and in wider society. It sets out the different ways in which it is unlawful to treat someone.

General equality duty and the CCG policy response

  • Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act.
  • Advance equality of opportunity between people who share a protected characteristic and those who do not.
  • Foster good relations between people who share a protected characteristic and those who do not.

To meet the general duty the CCG will publish its equality objectives and produce the annual equality information report. In doing so the CCG will:

  • Ensure policies and services are routinely impact assessed to eliminate and minimise any negative impact and remove any barriers.
  • Take steps to meet the differing needs of people.
  • Encourage participation of patients and the public in decision-making.

The Equality Act covers nine protected characteristics, which cannot be used as a reason to treat people unfairly. These characteristics refer to the groups of people who are specifically offered protection by the Act.


A person belonging to a particular age or age group. People of different ages include children, younger people and older people.


Both men and women are protected under the Equality Act 2010.

Gender Reassignment

People who are proposing to undergo, are undergoing or have undergone a process (or part of a process) to reassign their sex by changing physiological or other physical attributes of sex.


People who have a disability or a physical or mental impairment and it has substantial and long term adverse effect on an individual’s ability to carry out normal daily living activities.


People characterised by shared ethnicity, colour, nationality (including citizenship) and ethnic or national origins.

Pregnancy and Maternity

The law covers pregnant women or those who have given birth within the last 26 weeks, and those who are breast-feeding.

Marriage and Civil Partnership

In the Equality Act marriage and civil partnership means someone who is legally married or in a civil partnership. People do not have this characteristic if they are single.


In the Equality Act religion or belief can mean any religion, for example an organised religion like Christianity, Judaism, Islam or Buddhism; or a smaller religion like Rastafarianism or Paganism, as long as it has a clear structure and belief system. The Equality Act also covers non-belief or a lack of religion or belief.

Everyone in the UK is protected under the Human Rights Act 1998. The CCG, as a public authority, is obliged by law to respect the basic human rights of all citizens. As a public body we must at all times act in a manner compatible with the rights protected in this Act and safeguard these for patients and staff in our care and employment.

Human Rights are underpinned by a set of common values and have been adopted by the NHS under the acronym FREDA.

The FREDA principles represent:

  • Fairness (e.g. fair and transparent grievance and complaints procedures)
  • Respect (e.g. respect for same sex couples, teenage parents, homeless)
  • Equality (e.g. not being denied treatment due to age, sex, race etc.)
  • Dignity (e.g. sufficient staff to change soiled sheets, help patient to eat/drink)
  • Autonomy (e.g. involving people in decisions about their treatment and care)

Consideration of human rights is also given in our Equality Analysis process, to ensure that our policies and strategies are compatible with the rights afforded by this Act.

It is a specific duty of the CCG to publish its equality objectives at least once every four years. Our 2020-2025 equality objectives are based on three key principles:

  • Our statutory duty as a public sector organisation and what is required under the NHS mandatory standards.
  • Our health inequality duty as a CCG.
  • Local priorities based on our legacy work and the themes that have emerged from our equality impact assessments.

We implement our equality objectives through an annual action plan which will be developed by the Patient and Public Engagement and Equalities Committee, alongside relevant managers of the CCG.

Publishing equality information every year is a specific duty under the Equality Act. Our Equality Information Report provides information about how the CCG is meeting its duty to make continuous improvements in advancing equality for our patients and staff.

Our NCL CCG Boroughs’ Equality Information Highlight Reports 2018/19

Our NCL CCG Boroughs’ Equality Information Highlight Reports 2019/20

We commission our services mainly through NHS Trusts that are also required to comply with the Equality Act 2010.  

As part of our role as commissioner of care we seek assurance from our providers on how they are meeting the public sector equality duty and NHS England’s mandatory standards.

Our aim in 2020/21 and beyond is to focus on:  

  • Increasing collaboration with providers and commission co-production to ensure high quality of clinical care
  • Ensure equality in access to services by protected and vulnerable groups
  • Greater involvement of patients in the planning and delivery of the care that they receive
  • Ensure staff representation in senior management roles and staff experience of equality of opportunity in career progression and promotion, with a particular focus on race and disability.

NCL CCG has produced a two year single Diversity and Inclusion Strategy for 2021-23. The Strategy has been developed based on the CCG’s equality duty and the current and future health inequalities and workforce priorities. It includes two specific equality objectives on health and workforce inequalities with specific outcomes, and four system enablers to ensure robust and effective implementation. The CCG has engaged both internal and external stakeholders in developing these objectives and the enablers and has developed an annual action plan. The strategy is available here: NCL CCG Diversity and Inclusion Strategy.

Key priorities for 2020-2025

Based on local needs analysis, the CCG has identified the three key service priorities for equality duty. These areas will be the key focus for the annual action plan and Equality Delivery System (EDS2) grading.

As a CCG we are continuously exploring ways to improve equality in health outcomes for all our population. We put equality, diversity and human rights at the heart of all our commissioning decisions.

  • We will ensure all our decisions are equality impact assessed (equality analysis) and they are robustly completed focusing on three key components: equality and equity, engagement and health inequalities. Outcomes of our equality analysis will be fed into the equality action planning process and be shared with our stakeholders and providers as appropriate.
  • We will engage with our patients and carers from diverse backgrounds in commissioning. Our 2019-20 EDS2 grading and several EQIA outcomes have identified this as an area that needs further focused work.
  • We will continue to work collaboratively with our partners, the voluntary sector and providers to advance equality.

We recognise that promoting and supporting diversity in the workplace is an important aspect of good people management – it’s about valuing people in the organisation as unique individuals and offering them equality of opportunity in career progression and promotion.

Our aim is to have a workforce that reflect the local community we serve. To achieve this we will offer every staff member opportunities so that they can be the best they want to be – and they make our CCG a better commissioning organisation. 

We are focusing on three key workforce areas:

  • Recruiting staff from diverse backgrounds across all bands.
  • Supporting staff in employment so that they can give their best and feel valued.
  • Engaging staff in decision-making.

We will set up Staff Networks to support staff and help the CCG address issues facing our staff. Our People Plan will include specific measures and interventions on how the CCG can advance equality of opportunity for all and will include actions to improve staff experience.

The CCG recognises the importance of leadership in advancing equality and reducing inequality in care – and therefore will work to ensure the following:

  • Assurance – all commissioning decisions are based on robust equality impact assessments and Governing Body members are assured that ‘due regard’ to the equality duty has been demonstrated in the proposal or business case before it can be approved.
  • Stewardship – all senior leaders in the CCG will take individual responsibility to champion equality and inclusion and will ensure the delivery of the equality objectives.
  • Accountability – the CCG will deliver equality outcomes as mandated by NHS England, and agreed with local stakeholders and partners, to hold itself to account through the annual performance reporting.

Equality Diversity System (EDS2)

The Equality Delivery System (EDS2) is a national best practice toolkit that helps and supports NHS organisations, like CCGs, to monitor and improve the services they commission for local communities. EDS2 has four key goals, with 18 specific outcomes, which we are working with to improve the way in which people from different groups are treated as service users, carers and employees. The EDS2 is used by every NHS organisation in England which means they will be working towards the same set of equality and human rights goals.

Workforce Race Equality Standard (WRES)

The NHS Workforce Race Equality Standard was developed and introduced in 2015. Organisations are required to review and report against nine indicators.

The indicators are a mix of NHS staff survey data and the workforce data comparing the experience of BME and white staff. It also compares the governing body data with the workforce and local population data to show how representative the governing body is compared with the CCG workforce and the local population. We publish a progress report with an action plan every year. Our latest report is available below:

Our HR/OD and Equality and Diversity Teams work together to implement the WRES in the CCG. Currently the Equality, Diversity and Inclusion Working Group and the Executive Sponsor are responsible for developing the action plan and advice the CCG on provider assurance. NEL (Commissioning Support) provides support with gathering the data and updating it on behalf of the CCG.

We set our priorities to advance workforce race equality in the CCG and also to influence the agenda across our provider landscape on an ongoing sustainable basis. This is why we are working as a collective with our providers to share experience and ideas to develop common areas of priority. For the next three years our WRES priorities are:

Accessible Information Standard (AIS)

The Accessible Information Standard (AIS) aims to make sure people who have a disability, impairment or sensory loss get the information they can access and understand, and any communication support they might need.

This includes making sure people get information in different formats, for example, large print, Braille, easy read; and support such as a British Sign Language interpreter, deafblind manual interpreter or an advocate.

The AIS means that organisations providing health or social care need to ensure five things:

  • Ask people if they have any information or communication support needs, and identify how to meet them.
  • Record those needs in a set way on the patients’ records.
  • Highlight or flag in the person’s file or notes, so it is clear that they have information or communication support needs and details of how to meet those needs.
  • Share information about a person’s needs with other NHS and adult social care providers when they have consent to do so.
  • Make sure that people get information in an accessible way and communication support if they need it.

CCGs are exempt from meeting the standard. However, we are committed to the AIS, and we ensure that whenever we communicate with the public that we consider the requirements of the standard.

Our Communication and Engagement Team is responsible for making sure any information we produce is accessible – and they make reasonable adjustments for people who have an information or communication need. This applies to our published information on the website and all printed materials produced for engagement and consultation.

We also work closely with our member GP Practices to provide the necessary support to enable them to meet the requirements of the standard. The CCG continues to seek assurance from provider organisations about their compliance with the standard, including evidence of how they are planning to meet the standard.

More information on the AIS can be found on the NHS England’s website https://www.england.nhs.uk/ourwork/accessibleinfo