Strategic Equality Plan 2024 to 2028: summary of responses

What is the Strategic Equality Plan and why are we consulting on it?

The Strategic Equality Plan sets out our longer-term aim and our equality objectives over a 4 year period. The Welsh Government already works collaboratively with partners and members of our equality stakeholder groups. We want to use this wider public consultation to develop together National Equality Objectives and supporting actions (the interventions or the things that we will do to meet our Objectives) over the next 4 years, and at the same time, work to deliver our long-term aim for equality in Wales.  

The formal consultation opened 13 November 2023 and closed 12 February 2024.

Responses were received from a wide range of organisations (n = 56) and individuals (n = 10). A breakdown of the organisational responses is available in Table 1.

Question 1: Do you agree with the long-term aim? Please explain your answer, suggesting any amendments

62 respondents answered this question. 51 respondents indicated they agreed with the long-term aim, with 6 respondents not agreeing and 3 respondents signifying they were unsure. Agreement or otherwise could not be determined from 2 of the responses.

Multiple respondents (n = 8) referred to the long-term aim aligning with their organisational aim, with 3 respondents mentioning the aim being ambitious as part of their submission.

Whilst being in agreement with the long-term aim many respondents reflected on ways in which the aim could be improved. 

• 5 respondents referred to the long-term nature of the aim, with some suggesting that no definition was provided to indicate what long-term means, and others signifying that 2024 to 2028 is not long-term.
• 4 respondents argued that additional references to health inequalities within the Plan is required.
• 14 respondents referred to implementation, deliverability and actions being important. Suggestions to support this included:
  • undertaking evaluations/reviews
  • having a consistent approach
  • maintaining focus on what sits below when plans are high level
  • ensuring individuals within public bodies have skills, desire and understanding
  • having prescriptive actions
  • having clarity and actionable steps
• Multiple respondents (n = 7) highlighted accountability in the submissions, referring to having effective mechanisms in place as well as clarity and leadership. In addition, how the Plan would be enforced was mentioned and who would have responsibility for ensuring the aim will be achieved.
• 5 respondents adhered to the view that monitoring and evaluating the Plan was important in order to track progress.
• Concern was raised by some respondents (n = 7) regarding the fact that there is no compulsion to force local authorities and other public bodies to adopt the Plan as this could lead to:
  • a lack of alignment/consistency
  • citizens having little to no recourse when unhappy
  • impact on take-up
  • devaluing of the Plan
  • postcode lotteries in terms of what citizens can expect
• 3 respondents referred to use of the term non-discrimination in the Plan, with reference to how it is passive (n = 2) and it should be replaced with anti-discrimination (n = 2).
• The need for additional funding was raised by 4 respondents.
• 1 respondent referred to local authorities publishing their plans at a different time to the Welsh Government, with another respondent echoing this in terms of Health Boards.
• The importance of the interactions between the different plans was highlighted by 3 respondents.
• Engagement was mentioned by 3 respondents, with regards to people with lived experiences (n = 1) and stakeholders (n = 2).

Together with the above themes, the following points were raised as part of the consultation responses:

• helpful for there to be more references to specific United Nations Convention on the Rights of the Child (UNCRC) articles, would demonstrate the government applying their duty of due regard to children’s rights under the Rights of Children and Young Persons (Wales) Measure 2011, by ensuring that children’s rights are actively considered and acted upon in all their work
• belonging should be included in the long-term aim, this important element and goal for a society to thrive is often missed
• it is important to consider not only the beneficiary of an intervention but also the environment in which they are situated, such as public bodies
• a long-term approach may not create a sense of urgency, potentially causing delays in delivery due to distant deadlines
• many public bodies would prefer more structure, alongside clearer stipulations and expectations of what their equality plans should contain
• it is vital that access to justice is built into the Plan because, without that, equality and human rights cannot be guaranteed
• could place greater emphasis on structural change aimed at institutions, systems, and processes
• suggest adding an additional bullet point that reflects the importance of individuals having the agency, both over their own lives and their communities’
• the safety of women and girls deserves explicit mention in the long-term aim
• concern that framing both the long-term aim and the National Equality Objectives within several thematic areas creates unnecessary silos in policymaking
• important that the Plan recognises all parents, including Catholic parents, have the right to educate their children based on their faith and beliefs
• there are 2 different long term aims which is confusing (1 on page 22 and 1 on page 25)
• concern about whether marginalised groups should have greater access as they experience multiple disadvantage and discrimination, could potentially be recognised within the Plan so that additional weighting is given to fulfilling the National Equality Objectives in a way that proactively addresses intersectionality
• balancing aim with local, regional and global considerations leading to implementation challenges and hindering impact, need to have flexible approach to adapt to local needs and international best practices
• need to implement robust change management strategies, including awareness campaigns and education programs to foster understanding and acceptance, and address resistance
• fail to clearly distinguish between “equity” and “equality” and therefore the aim is unclear
• what areas of Wales would be particularly focused on (both systemically and geographically)?
• what impact will role of UK government have on the Plan and its effectiveness?
• derivations could be considered focusing on being active rather than passive switching from affording equity, non-discrimination and inclusion to recognising the active role people play in achieving this aim
• would like to see carers be identified and recognised for their role within the community and their contribution to Wales
• how can the Plan strengthen equality impact assessments to ensure they are meaningful and robust?

Of the 6 responses to the consultation that did not agree with the long-term aim, 4 originated from individuals, with the remaining 2 not specifying whether they were an organisation or an individual as part of their response. Reasons for not supporting the long-term aim included it being unnecessary (n = 2) and it not being possible for all citizens to be recipients of fairer outcomes (n = 1). In addition, one respondent referred to the needs of females not being accommodated or even considered seriously, whilst another made the point that achieving a fairer society should not be at the cost of other freedoms, whereby if individual freedom is lost due to a nanny state dictating every move being made then inequality becomes built into the system.

Question 2: Do you agree with the proposed National Equality Objectives above? Please explain your answer, suggesting any amendments

66 respondents answered this question. 51 respondents indicated they agreed with the proposed National Equality Objectives (NEOs), with 7 respondents not agreeing and 3 respondents signifying they were unsure. Agreement or otherwise could not be determined from 5 of the responses. 

The vast majority of responses to this question are lengthy and very detailed, and this summary of themes from responses needs to be treated as a collation of common themes rather than an extensive list of respondents suggestions for amendments. Due to the differing means of collection the responses were not standardised and varied greatly in how they approached answering the question, therefore themes have not generally been collated around specific NEOs unless specifically relevant to point.  

Of the 66 respondents 1 accepted the NEOs fully with no comment and 11 provided no specific comment on the NEOs meaning the following analysis is based on 54 responses.  

The necessity of the NEOs to be underpinned by robust and measurable policies, strategies and legislation was a strong theme across responses (n=23).  

Respondents identified the importance of data collection (n=6) highlighting the need for better and more efficient data collection. A suggestion of incorporating mandatory data collection in relation to socio-economic backgrounds of employees to better reflect the composition of the workforce in Wales was mentioned in 2 responses and individual comments in relation to a need for a legislative base for the commitments around human rights, public transport and employment.  

Respondents identified a lack of synergy within the NEOs with existing strategies (n=16), with alignment to the thematic goals of ‘Is Wales Fairer 2023’ mentioned in particular (n=4).  

The lack of an associated Equality Impact Assessment was noted by 2 respondents.  

Respondents identified that the NEOs as proposed are not clear or measurable (n=11). They felt the Plan lacked detail on how the NEOs would be achieved and how we would know they had been achieved, whilst there was a belief clear steps with associated timelines attached to them and a clear outline of how progress would be measured was missing. One response commented that the NEOs currently ‘read as overarching aims’ rather than objectives ‘that provide clear steer for public bodies’.  

The language in the report was criticised by respondents as ambiguous and lacking in commitment (n=11). The following is a sample of the criticisms:  

• too many undefined words and phrases
• not clear who owns what objective and who is responsible
• words such as ‘awareness’, ‘encourage’ and ‘understanding’ do not create change or show a commitment to ensure rights are met
• the language within the objectives is passive and needs to be active
• words such as ‘levers’ need to be qualified

Health inequalities was a strong theme within the responses (n=16) with respondents feeling that it needed to be specifically mentioned and addressed within the NEOs (there was no consensus on which NEO as respondents were commenting from different angles) and some (n=3) stated that it needed it’s own objective.  

Intersectionality was another common theme, with respondents feeling that it was not focused enough and needed more explicit consideration (n=11). It was identified that there was a lack of underpinning discrimination law advice or centres for intersectional advice and support in Wales, undermining the commitment.  

NEO 5 and NEO 6 were frequently grouped together in responses. 7 respondents felt that the themes overlapped to such an extent that they should be merged. 15 respondents raised specific issues in relation to the presence of ‘public transport’ in NEO 5 finding it out of place and not linked to any of the aims/actions. Respondents emphasised how important they felt accessible and affordable transport was in achieving all of the NEOs and some (n=5) felt that transport needed to be added as a separate NEO. One respondent raised that current public transport was unsuitable for vegans, due to fuels and textiles used.   

Some (n=6) people felt that NEO 5 was too narrow in its description and needs to be widened to include – use of community resources, access to health, GP registration etc. 

There was a specific theme of lack of clarity and confusion in relation to NEO 5 and 6 with people struggling to understand what these particular NEOs were aiming to achieve, how they would be achieved and who was responsible.  

Concerns around resources featured in many of the responses (n=17) with respondents feeling that many sectors had already faced huge cuts in recent years and the delivery of the NEOs was unrealistic without substantial increases to funding and resources. The third sector was highlighted as an important part of being able to deliver on the NEOs however it was identified they had faced the most cuts. The cost of living crisis was mentioned as a further barrier to the achievement of the NEOs as poverty would drive an ever increasing number of people into services seeking help however these services are already not able to meet demand.  

The lack of specific focus and attention on protected characteristics was flagged as a concern by 11 respondents.  

8 respondents did not think that the NEOs paid enough attention to poverty and how it disproportionally impacts some groups in society (children, deaf community, people with protected characteristics).  

Housing featured as a theme in 5 of the responses, with respondents commenting that there was a failure to address the housing crisis and how pivotal addressing this was to achieving the NEOs.  

14 respondents commented on the need for structural challenges and systemic inequalities to be addressed and did not feel the NEOs provided a clear picture on how this would be achieved.  

The focus on lived experience was positively received (n=8) with respondents applauding the sentiments and inclusion but emphasising the importance of putting the structures in place to facilitate this and ensuring that it was true co-production, with people properly compensated for their time and experience. One respondent noted that given the high likelihood of those with lived experience being on welfare benefits the Welsh Government needs to rectify the current situation of benefits being negatively impacted when people receive compensation for taking part in co-production.  

NEO 7 received notably less comment than the other NEOs and generally was positively received however a few (n=3) felt that the considerations of climate change needed to be stronger and some (n=9) raised concerns that certain groups were impacted disproportionally by climate change and therefore needed specific consideration (black, Asian and ethnic minorities, disabled people, people with protected characteristics, women, the poorest in our societies, vegans). A respondent also raised that the environmental sector is particularly lacking in diversity, and this should be highlighted as an area for improvement. 1 respondent felt that NEO 7 should not be included at all as it was a ‘wasteful expense’.  

Welsh language provision and its importance was highlighted by 2 respondents.

Question 3: Please tell us about any other issues relating to equality and community cohesion in Wales that you feel should be addressed?

57 respondents answered this question. This question was an open question. The following themes were collated from lengthy and detailed submissions.

Some comments (n=5) suggested that more needs to be done to address digital exclusion. It is acknowledged that gradually more public services are provided online, underscoring the importance of fostering communities equipped with both adequate digital access and skills. This especially affects those living in rural areas with poor digital connectivity. Responses emphasise that considering the budget cuts to the Digital Communities Wales programme, there is a need for the Strategic Equality Plan to include actions to combat inequalities stemming from digital exclusion and poverty. 

5 respondents raised the need to improve public awareness, understanding and attitudes towards disability. This is believed to help remove societal barriers and foster integration. 

Comments (n=4) called attention to the growing gap between disabled and non-disabled people especially in education attainment and employment. Respondents also called for tackling the ongoing impact of the COVID-19 pandemic, which persistently widens the gap. 

Children and young people with additional learning needs also missed out on 3 years or more of specialist educational support such as Occupational Therapy, Speech and Language Therapy and more as a result of school closures and changing of lessons to ‘online’ provision. As a result of this support gap in learning during the 2020 to 2021 window, many of these children and young people with learning disabilities lost the crucial support in their development and educational years. (S15) 

Some respondents (n=4) agreed on the need of supporting families with children and young people with physical and learning disabilities. It is discussed that, services often fail to engage families, leaving them to navigate the challenges of interacting with their children and broader society on their own. This also has an effect on financial distress. 

Starting at birth, the vast majority of deaf babies and their families in Wales receive no support whatsoever with learning British Sign Language (BSL). Welsh families have to pay to learn to communicate with their children (S21). 

The Plan needs to recognise that for a lot of disabled children and young people it is their families that will be supporting their engagement, and services should understand how to work with the whole families, from diagnosis, to school, employment, housing, social and civic engagement and beyond (S13).

Respondents (n=3) called for equal access to public transport. Older people and disabled people are facing difficulties in accessing public transport especially in rural areas. 

Several respondents (n=6) adhered to the view that intersectionality was missing or inadequately addressed. It was suggested that all 9 protected characteristics should not be treated as a homogenised group, but rather with tailored support, resources, and opportunities to achieve equitable outcomes. 

5 respondents highlighted that the Plan’s objectives should explicitly demonstrate its impact on mental health and wellbeing, especially in terms of showing different approaches for various groups. Respondents mentioned children and young people, LGTBQ+ individuals, disabled people, and those living in the most deprived areas of Wales specifically with regards to this. 

Concern was raised that the Plan seemed to fail in setting more explicit objectives and actions to tackle health inequalities. Many respondents (n= 6) built on the link between health, poverty, and inequality. 

Several respondents (n=4) referred to the lack of focus around human rights legislation and commitment. 

Most responses expanded on the need for detailed and tangible actions that have the potential to provide guidance and leadership to bodies involved in the implementation of the Plan. Nevertheless, it was highlighted by 7 respondents that the implementation would not be possible without additional funding allocated to local authorities or third sector organisations. 

Together with the above themes, the following points were raised as part of the consultation responses:

• 2 respondents highlighted the need to build a trauma informed society
• 2 respondents highlighted that the Plan failed to recognise adequate housing as a way to tackle inequality. 2 respondents called for safe housing options for women escaping domestic violence
• multiple respondents raised the need to tackle various forms of discrimination, with each respondent highlighting a different aspect: ageism, islamophobia, inter-ethnic racism, bullying in educational settings, discrimination against other types of education, and discrimination against non-Welsh speaking citizens
• 1 respondent called for the need to include youth homelessness in the Plan
• 1 respondent believed in a stronger focus on gender parity and the role of equitable research in policy and decision making
• 1 respondent argued for the need to tackle youth homelessness

Question 4: Do you believe having the proposed principles of approach strengthens the Strategic Equality Plan?

59 respondents answered this question. 37 respondents indicated they agreed the proposed principles of approach strengthens the Strategic Equality Plan, with 7 respondents not agreeing and 5 respondents signifying they were unsure. Agreement or otherwise could not be determined from 10 of the responses.

Multiple respondents (n = 9) referenced in some way the principles of approach addressing cross cutting themes, providing a framework for action, acting as an overarching document, drawing together different plans and policies in a coordinated way to avoid duplication and ensure consistency in delivery. 3 of these respondents also called for additional detail to be provided in terms of the coordinating role performed by Welsh Government and how the strategies, plans, objectives, principles, outputs, outcomes, activities will come together over the next 4 years to reduce inequalities.

5 respondents mentioned legislation / regulation as part of their submissions, referring to how they affect the equality goals, how they can be applied to achieve better outcomes and how they can be used to address non-compliance

The importance of engagement was highlighted by 11 respondents, with reference to the need for better relationships, targeting a variety of people / stakeholders with lived experience / vested interests, taking action as close to the local community as possible, and the need for early engagement at the outset of Plan / policy development, 

8 respondents raised the issue of Equality Impact Assessments (EqIAs) in answering this question. One respondent called on the Welsh Government to provide public access to all EqIAs, whilst others referred to the leadership role Welsh Government can play in ensuring EqIAs are undertaken by each government department and local authorities, concern around EqIAs being conducted after the decision has been made, and the need for improvements to the EqIA process.

Resources were referred to by multiple respondents (n = 9), including the need for adequate resources to be made available to support implementation, and concern that local authorities and third sector are expected to deliver with limited resources.

12 respondents signified the importance of measuring progress, with reference to:

• measurable indicators / targets
• monitoring frameworks and evaluations
• the lack of targets and tools / methods making progress difficult to measure
• the need for regular monitoring, review and engagement
• annual reporting of public bodies’ progress against National Equality Objectives

The need for tangible actions / outcomes was flagged by 9 respondents. 

Many respondents (n = 8) raised the point of ensuring accountability for meeting the principles, including compliance by local authorities and public bodies.

The importance of research and data was referred to by some respondents (n = 5), with reference to whether research on the implementation gap has been undertaken, the need to ensure the voices of the most vulnerable are heard and the lack of data that exists.

3 respondents argued that these principles should already be in place. 

Together with the above themes, the following points were raised as part of the consultation responses:

• proactively accounting for the underlying factors that contribute to inequalities, such as the building blocks for health, will help mainstream equity in the design and delivery of Welsh Government interventions and policy development
• principles of approach are vague and need further work to be effective
• welcome intersectionality principle but would encourage a greater focus on how characteristics interact to produce different challenges or service needs, rather than joining up thinking at a policy making level. i.e., focusing on the individual rather than service
• only work being undertaken directly under the mandate of the Minister for Social Justice is included. We would recommend a cross governmental approach to equality
• encourage Welsh Government to look to its work in other sectors to give a full broad equality strategy as is intended here
• when dealing with complex problems, simple solutions may not be sufficient, and therefore the preferred approach would be to use multiple methods. While there may be a disadvantage to limiting the scope of those who are helped, designing for the most vulnerable ultimately benefits everyone. However, focusing on the most impactful root cause of inequality may significantly improve the lives of many people and enhance services for others
• would query how far these principles will be embedded in the working of public sector delivery partners, given that the current draft of the Plan seems to not make any stipulations in this regard
• not convinced that they will live up to their full potential unless they are integrated into a set of National Equality Objectives that fully reflects the new role of the Strategic Equality Plan
• given that the Plan’s focus is high level, and is supported by other programmes of work, it is not clear whether including additional working principles will support the delivery of the Plan
• appreciate a ‘living document’ helps policymakers adapt to changing needs, which is important, but concerned this may impact both target setting and scrutiny - welcome the commitment to an annual report on the progress of the Plan, however
• appreciate the Plan aims to look at change over the longer term, with a view to building on the previous plan and working towards the long-term aim
• needs to be more clarity around spending within specific business expense lines (BELs) to improve transparency and scrutiny
• encouraging that Welsh government is cognisant of the gap between intention and delivery in policymaking, particularly given the scale of the task in improving equality in Wales in a meaningful way
• rightly reflects the need for the Plan to be able to swiftly react to changes in the policy environment
• welcome the transparency demonstrated in the approach
• encouraged by the commitment and involvement across Welsh Government to implement this Plan
• instead of stating ‘we will aim to..’ using ‘we will’ would be stronger language that indicates the resolution to address the implementation gap
• enables the strategy to remain relevant to actions that might be developed in future across various minority group work programs
• acknowledging and addressing intersectionality ensures that policies and interventions are tailored to the complex and varied experiences of individuals, promoting more equitable outcomes
• needs of biological women are ignored
• no clear rationale relating to the choice of principles
• as with the long-term aim and the objectives they are aspirational, and consideration needs to be given to the realistic achievements that can be made within 4 years
• principles don’t include enablers to facilitate people seeing others as individuals, people need the skills to do this, how do we provide those skills?
• ambitious given finances currently
• how is this Plan being embraced by all ministers at Welsh Government?

Question 5: If so, do you agree these are the right principles of approach? Please explain your answer, suggesting any amendments

Analysis is based on 62 responses. 35 respondents agreed these are the right principles of approach, whilst 6 respondents disagreed and a further 5 indicated they did not know. Agreement or otherwise could not be determined from the remaining 16 responses. 

Of the people who agreed (n=35), respondents praised the intersectional approach and the intent to draw together and connect wider equalities work, reducing duplication and silo approaches to addressing inequalities. 

Of the respondents that disagreed (n=6), criticisms centred around an empty rhetoric with 1 respondent feeling it ignored the rights of biological women.

The following themes were gathered from respondents who provided additional comment for the question (n=41). 

The strongest theme that emerged from the consultation responses was around the structures that would underpin the principles, with respondents (n=14) raising concerns that no clear information was provided on how the principles would be enacted. Respondents believed there needed to be a clear framework attached to the principles that would set out how the principles would be achieved accompanied by clear timelines, milestones, accountability, mechanisms for other sectors to lead and contribute, and concrete plans for monitoring, reviewing, and evaluating. Respondents (n=2) also raised concerns about levels of resourcing needed to enact the principles. 

EqIAs were noted as an important mechanism of ensuring principles were enacted, with this mentioned specifically by 9 respondents. They were seen as a way to demonstrate meaningful engagement with different groups and communities. Respondents felt that public access should be provided to the EqIAs to improve transparency. Concerns were raised about the quality and consistency of EqIAs currently and respondents felt that they needed to be strengthened.

Respondents (n=5) commented on language within the principles not being strong or clear enough. A specific suggestion was offered around the use of ‘mainstreamed’ as the respondent felt it was too similar to other terminology in use within the equality sector, feeling that it would be better to substitute with the word ‘embed’. 

9 respondents provided specific feedback in relation to amending or adding specific principles. Suggestions for additional principles included:

• a principle of working towards minority leadership on matters most closely affecting these minorities
• a fourth principle to be included, with specific regard to analysis, feedback and outcomes
• add a further principle ‘to improve public understanding of equality and its benefits for all’
• a principle around early intervention

The following amendments were suggested: 

• amend third principle to ‘Empowering marginalized groups so Wales rapidly transitions to equality for all
• tailor the principles to specifically address youth homelessness and domestic abuse
• revise the first principle to embed due regard to the Public Sector Equality Duty
• include additional objectives relating to ‘Diversity in Democracy’ and early intervention work within communities
• combine principles 2 and 3 to cover, ‘to be able to be refreshed to take account of emerging policy direction and equality impacting legislation, whether made in Wales or, more widely, across the UK’

While the above themes capture some of the consensus across the answers to question 5 there were many points raised within individual responses that did not sit neatly within them. The following provides a summary of these individual comments: 

• the socio-economic duty is essential to delivering on the principles
• need to avoid pinpointing specific protected characteristics (n=2)
• need to specifically focus on protected characteristics (n=2), faith and philosophical belief
• intersectionality needs to be more focused at the individual level rather than at the sector level
• believe that research needs to be undertaken to establish why the gap between implementation and delivery exists so that addressing it can be approached in an evidence based way
• co-production needs to be specifically focused on (n=2)
• important service providers are consulted on the challenges faced in implementing policies and plans
• an independent committee made up of people with lived experience and professional experience of equality and protected characteristics should be set up to hold the Welsh Government to account and provide suggestions of implementation of the strategy
• the British Deaf Association (BDA) offered 2 specific pieces of feedback in relation to Deaf BSL signing people
• we request the Welsh Government to commit to creating a 5 year plan (in close collaboration with the BDA) to upskill Welsh Deaf BSL signers into taking on responsibilities for designing, delivering, managing and evaluating BSL related matters in Wales
• the BDA believes that Deaf BSL signing people have a nuanced and deeply intersectional / dual category status as both a disability minority and a language minority. Often BSL services are provided using disability funding, and vice-versa. This intersectionality can cause much confusion and can be difficult to unpick; and has been used to deny Welsh Deaf, signers from taking leadership on decision-making and policymaking on BSL and Deaf issues. This creates poor outcomes

Question 6: Do you believe the National Equality Objectives will help us fulfil the Socio-economic Duty? Please explain your answer

55 respondents answered this question. 36 respondents indicated they agreed that the NEOs will help fulfil the Socio-economic Duty (SED), with 10 respondents not agreeing and 4 respondents signifying they were unsure. Agreement or otherwise could not be determined from 5 of the responses.

While agreeing that the NEOs will help fulfil the SED, many respondents (n=10) reflected that not all NEOs demonstrate a direct correlation to the SED. Responses varied, with some indicating only 1 to 3 NEOs had a clear connection. 

5 respondents argued the importance of ensuring that each goal demonstrates its relevance to the SED. A number of respondents (n=7) advocated for the inclusion of detailed actions underpinning the objectives to understand their practical impact on fulfilling the SED. 

Some respondents (n=5) highlighted the critical role of robust, high-quality data collection, emphasising the necessity for analysis through an intersectional lens. Two respondents expressed the belief that there is currently a lack of data collection regarding socio economic backgrounds, such as a lack of information on disabled people.

The requirement of monitoring, evaluating, and measuring the success of the NEOs in relation to the SED was a strong theme (n=10). 3 respondents added the necessity to measure the present impact of the SED considering it is not showing major improvements. 

6 respondents stated that the prevailing financial challenges in Wales, such as the impact of the pandemic or the cost-of-living crisis, present difficulties to fulfilling the SED. The NEOs must recognise this situation and build upon it. 

Concern was raised by some respondents (n=7) regarding the challenge of delivering due to the financial cuts in public services and the rising cost in social care and education. Without substantial increases to funding and resources, fulfilling the SED seems ambiguous and unrealistic. 

7 respondents raised the necessity for a transformation in the collaboration with the public sector. They advocate for holding them accountable not only for compliance with the NEOs but also for substantiating their decision making with evidence. 3 respondents raised that this could lead to decision-making from being primarily driven by financial efficiency and crisis management to strategic, long-term commitment to the SED. 

Some respondents (n=4) emphasised the value in engaging with people with lived experiences to understand the intersectional issues and including them in the decision-making. 

The following points represent proposals put forward by separate respondents: 

• a greater emphasis on health could help NEOs fulfil the SED, the lack of provisions and treatments result in people with illnesses having to leave the workforce or being unable to re-enter
• improve the quality of education in deprived neighbourhoods
• consider integrating a family-centred approach when assessing socio-economic impact
• consider issues related to housing
• consider issues such as fuel poverty, hygiene poverty, and generational poverty
• improve access to services for women and disabled people to increase chances to contribute to the economy
• consider the intersection between economic disadvantage and abuse (‘Women are less able to escape poverty, and this is more so the case for women who have multiple support needs such as those who have experienced a form of violence against women. This is particularly true for Black and minoritised women, older women, Deaf and disabled women, and LGBTQ+ women’)
• consider including statutory guidance on providing support for people with learning disabilities in work
• consider proposing employers measure the socio-economic background of their employees and potential recruits
• support employers to give fulfilling employment opportunities for people with learning disabilities
• improve access of public to transport for disabled people to facilitate seamless commuting to work

Question 7: Do you believe the National Equality Objectives will help to promote and embed human rights in Wales. Please explain your answer

55 respondents answered this question. 22 respondents indicated they believed the National Equality Objectives will help to promote and embed human rights in Wales, with 9 respondents not believing this and 5 respondents answering that they did not know. In 19 of the responses to this question it was unclear whether the respondent believed the National Equality Objectives will help to promote and embed human rights in Wales.

10 respondents referred in some way to the implementation of the Plan, suggesting that success in terms of promoting and embedding human rights is dependent on this, and calling for further detail on how implementation will be achieved in practice, including the need for timescales to be provided.

The need to measure and monitor the Plan in relation to human rights was raised by 6 respondents, whilst 2 respondents referred to the need for enforcement of the Plan.

A number of respondents (n = 11) specifically mentioned United Nations (UN) conventions at some point in their response to this question. Some respondents indicated they welcomed the commitment to incorporate the UN conventions related to disabled people, women and children into Welsh law, whilst other respondents felt these commitments are “watered down” in the Plan with no explicit mention of how incorporation into Welsh law will take place. Other references to legislation were made by 10 respondents, with some calling for the Plan to focus more on human rights legislation.

6 respondents signified they welcomed raising awareness of human rights, whilst 2 respondents referred to the need to explain in the Plan what is meant by human rights and that they are relevant to everyone. Multiple respondents (n = 10) called for the Plan to go further by making it clear how people can take action when their rights are infringed, including the need for the provision of tools / means to challenge and resources to support this, suggesting that raising awareness of human rights on its own is insufficient.

Extending the due regard duties so public bodies are required and not merely encouraged to promote and embed human rights was called for by 2 respondents, whilst 4 respondents raised the point of needing to collaborate with partners / stakeholders / communities so that everyone buys into the Plan and helps maximise its impact.

17 respondents referred to the Plan needing to support particular vulnerable groups, including:

• ethnic minorities
• disabled people, including people with learning disabilities and those who are deaf / use BSL
• women
• refugees and asylum seekers, including people with no recourse to public funds (NRPF)
• homeless people
• survivors of VAWDASV
• LGBTQ+ people
• old people
• children / young people
• patients
• care support workers
• people practicing religions and holding beliefs, including vegans
• people with electro sensitivity / Electromagnetic Hypersensitivity (ES/EHS)
• people living in rural areas

7 respondents indicated the Plan was missing something, including:

• a recognition that good housing is fundamental to achieving all facets of the Plan
• an objective regarding health
• the integration of belonging within the National Equality Objectives where relevant
• data, without an adequate sample size, it is not possible to draw statistically significant differences, which in turn makes it impossible to observe trends and create interventions where needed. This may be a human rights issue that requires a creative approach to address. Community groups can be approached with the aim of improving standards of living using the data we collect. Follow-up meetings should be arranged with community groups, and community members can also receive training on collecting social research data
• a clearer defined commitment to the social model of disability in Wales
• tackling inequality in social care
• the right to breathe clean and the right to rehabilitation
• an explanation of how the Welsh Government uses the concluding observations (where appropriate within devolved competencies) from the 7 Conventions that the UK has ratified

Together with the above themes, the following points were raised as part of the consultation responses:

• people don’t know where to go for help and support re. human rights
• if the proper accountability mechanisms are put in place, putting a responsibility on decision-makers to provide evidence of human rights compliance and scrutineers to be aware of and trained in their responsibilities to scrutinise strategic plans against human rights legislative requirements
• resource allocation and adequate resources for support services and collaboration with relevant organisations are crucial
• the listed aims could be stronger. Currently, they are written in a more passive than active language, which may not give the reassurance needed that the aims will be fulfilled
• consider taking out “in our villages, towns and cities across Wales”, and just include “throughout Wales” as communities aren’t just geographical places
• unsure as to whether, in the statement “We will create a Wales where everyone can be aware of their human rights, where they are protected, promoted, and underpin all public policy” this refers to Welsh Government or the people of Wales. Could this be reworded in some way?
• concerned about the lack of meaningful engagement in the CRIA (Children’s Rights Impact Assessment) process and hope the inclusion of this objective would encourage the use of CRIAs at a more in-depth and meaningful level and through a considered and proactive approach across government
• a potential model which Welsh Government could adopt or draw inspiration from is the European Pillar of Social Rights Action Plan. The European Pillar of Social Rights sets out 20 key principles and rights essential for fair and well-functioning labour markets and social protection systems, aligning strongly with many of the ambitions listed in Welsh Government’s Strategic Equality Plan, such as those to do with fair employment. The principles are set out as concrete actions alongside headline targets to be met by the EU by 2030. Delivery is shared across EU institutions, national, regional and local authorities, social partners and civil society
• in Germany private sector businesses can sign up to the Charta der Vielfalt, a corporate initiative to promote the recognition, appreciation and integration of diversity in business culture. The creation of a similar diversity charter in Wales could help drive towards the aims and objectives of the Strategic Equality Plan, while also boosting the success of businesses and making them more attractive employers by making use of the diversity of their employees
• the expression “intersectional advice” is a somewhat unconventional use of the term intersectionality, suggest that the idented action can be better conveyed if reframed as “work to ensure that people are aware of their rights and know where to find appropriate advice and support, including advice and support tailored to those who experience intersecting forms of discrimination.”
• the Right to Rehab is intrinsically linked to the Right to Health. It is not possible to obtain the highest attainable standard of health without access to rehab - Services such as rehab should be available to all, accessible to all, acceptable (i.e. appropriate) and of high quality
• could include an additional NEO focused on human rights or reviewing the “we will” actions generally to ensure one or more of them directly relate to promotion of the Human Rights Charter and similar actions
• important that any approach adopted is understood by all population groups. Work on cohesion is critical to reducing community tensions. Actions to promote awareness are likely to be more effective if these address all Welsh communities
• ensuring objectives are not only aspirational but also deliverable is crucial
• balancing the diverse needs of different communities may present challenges, and it's important to listen to feedback and adapt strategies accordingly
• don’t believe that the Welsh Government understands or fulfils the requirements of the Human Rights Charter
• unclear what you really mean to do. Equity? Equality? When do you mean equity? When do you mean equality?
• should Wales push to gain more power in this area or have its own rights charter, given the fact that this and related topic areas are reserved to the British Government?
• much depends on the care with which conflicting demands are met and managed
• helpful to have a grid with references between human rights and objectives and then to follow this with a comprehensive set of actions to understand what this means in practise for government
• the document does not reflect commitment to human rights as per the Programme for Government
• lack of focus on human rights
• not a particularly ambitious document
• lot of talk in Wales re incorporating human rights but the Plan seems to be more based on equality rather than human rights

Question 8: Do you have any further specific points you’d like to raise in relation to the Strategic Equality Plan? 

59 respondents answered this question. This question was an open question. The following themes were collated from lengthy and detailed submissions.

The strongest theme (n=22) that surfaced from the consultation responses was around the development and design of the Plan. Some respondents welcomed its goal of consolidating various plans, seeing it beneficial for public bodies to grasp the interrelation of the different plans and prioritise equality initiatives collectively rather than pursuing individual objectives. Nevertheless, many respondents expressed their concerns about the Plan potentially becoming a mere mapping document, lacking commitment to deliver realistic and specific results. 

5 respondents emphasised the need to implement realistic timeframes for both this Plan and others aligned to it. They raised the necessity for time-specific detailed actions to ensure effective implementation. 

12 respondents called for the monitoring, evaluation and reporting of the outcomes and commitments of the Plan through impact assessment. Establishing metrics for successful implementation is seen as crucial to demonstrate significant progress and achieve meaningful, real-world impact. Furthermore, some respondents wanted to see the rationale behind the chosen measurements. 

Some respondents (n=5) highlighted that monitoring could improve accountability for both the Welsh Government and other public bodies. Two respondents agreed that the Plan and equality should be treated as other legislative responsibilities. 

Greater detail on data collection was another topic raised. Respondents (n=5) want to comprehend how and which equality data will be collected, analysed and used to inform decision-making and measure progress. Another respondent believes it will help public services to design and commission systems that collect the relevant data. 

Further detail on co-production and how it will happen was also requested, as it’s considered another crucial source of data for the development and implementation of the Plan. Collaborating with the public and particularly with local authorities to tailor the principles to the local context was considered essential. However, 5 respondents raised concerns that funding and resources allocated to these bodies and other services will ultimately determine the success of the Plan’s delivery. 

Together with the above themes, the following points were raised as part of the consultation responses:

• 2 respondents expressed their concerns on terminology regarding ‘A healthier Wales: a society in which… choices and behaviours that benefit health are understood.’ and ‘Health: enabling personal responsibility’ as the language places responsibility on the individual and limited responsibility on public bodies for ensuring health and safety of citizens
• 2 respondents suggested considering embedding health impact assessment within the Plan
• 1 respondent suggested adding the principle of ‘positive action’ as the sixth ‘way of working’
• 2 respondents suggested taking into account the findings of the most recent ‘Is Wales Fairer’ report within the Plan
• separate individual respondents raised different missing areas of the report, including:
  • rural poverty
  • work poverty
  • health inequalities
  • housing and social housing
  • access to social care particularly around older people
  • the disproportionate effects of COVID-19 on different groups
  • support for independent living
  • the shrinking opportunities for young people
• different respondents raised the need to include targeted support for:
  • unpaid carers
  • women, especially women who suffer domestic abuse
  • those facing disadvantage or discrimination and not possessing a protected characteristic, like the Armed Forces community or looked after children
• different individual respondents recommended the incorporation of the Istanbul Convention, the CEDAW (Convention on the Elimination of All Forms of Discrimination Against Women), the United Nations Convention on the Rights of People with Disabilities, the Human Rights Act 1988 or the Rights of Children and Young Persons (Wales) Measure 2011, GOWA 2006 Section 77, VAWDA and other relevant International Conventions and Covenants e.g. UNCRC or UNCRDP
• 1 respondent suggested forums for sharing good practice in regions and service areas would be incredibly helpful to support grassroots organisations in the implementation of the Plan
• 2 respondents called for initiatives to raise awareness of the Plan and rights, yet another respondent believes that “SEP places great faith that increasing awareness improves policy making and produces better outcomes but research shows that focus on knowledge and awareness alone are not effective in changing cultures and behaviours”