Conduct a DPIA (UK GDPR Art 35) and maintain ROPA (Art 30) for equality monitoring. Determine lawful basis (Art 6) and Art 9 condition per context: use Art 9(2)(b) + DPA 2018 Sch 1 Pt 1 for employment; Art 9(2)(g) + Sch 1 Pt 2 para 8 (Equality of opportunity) with an Appropriate Policy Document (APD) for statutory/public interest monitoring; or Art 9(2)(a) explicit consent for voluntary initiatives. Ensure clear privacy notices, 'prefer not to say' options, and data minimisation.

Documented EDI policy/strategy

Define EDI governance: appoint an SMT lead and a Board trustee sponsor; include EDI in the risk register; conduct quarterly management reviews and annual board deep-dives on equity gaps and action plan progress.

Mandate Equality Impact Assessments (EqIAs) for all new policies, services, and major projects (define thresholds, e.g., >£X budget or eligibility changes). Use a standard template covering: evidence/data, consultation, impact on protected characteristics (access/experience/outcomes), mitigations, and monitoring. Require sign-off by the EDI lead and SMT.

Define and justify a 'Minimum Equity Dataset' for staff, volunteers, and beneficiaries (e.g., age, ethnicity, disability, sex, socio-economic proxy) based on service relevance and data minimisation. Monitor on a voluntary basis, applying small-number suppression (<5) in reports to protect privacy.

Maintain an Accessibility & Reasonable Adjustments Standard: meet WCAG 2.2 AA for digital interfaces; provide accessible formats (e.g., Large Print, Easy Read) and interpretation where needed; establish a tracked process for reasonable adjustment requests with defined response SLAs.

Training on unconscious bias and inclusive leadership

Annual reporting on diversity data and action plan progress.

Publicly available EDI report

Benchmarking against sector/community demographics

Inclusive recruitment/engagement practices

Use lawful positive action (EqA ss.158–159) with documented rationale (e.g., targeted outreach, tie-break provisions), structured interviews, diverse panels, and job adverts with essential-only criteria.

External accessibility audit and user testing with diverse groups.