Memorandum 51
Submission from the Equality and Human
Rights Commission
1. The Equality and Human Rights Commission
(the Commission) was established on 1st October 2007 under the
Equality Act 2006. It champions equality and human rights for
all, works to eliminate discrimination, reduce inequality, protect
human rights and build good relations, and to ensure that everyone
has a fair chance to participate in society.
2. The new Commission brings together the
work of the three previous equality commissions, the Commission
for Racial Equality (CRE), the Disability Rights Commission (DRC)
and the Equal Opportunities Commission (EOC). The Commission's
remit now covers race, disability, gender, gender reassignment,
age, sexual orientation, religion or belief and the application
of human rights. Working across Britain, the Commission has offices
in Manchester, London, Cardiff, Glasgow and Edinburgh.
INTRODUCTION: THE
POTENTIAL OF
SKILLS TO
IMPROVE LIFE
CHANCES
3. The potential of skills acquisition to
improve employment opportunities, tackle disadvantage and poverty
and to change lives for the better is well evidenced. If skills
can be secured even for those currently most distanced from them,
then these ambitions could become a reality. Leitch proposals
for increasing skills levels and subsequent implementation plans,
have set out an exciting agenda for delivery of change by 2020.
4. It is encouraging that the implementation
plan recognises the equality and diversity agenda that needs to
be set and addressed through implementation policies and practices:
"The skills deficits in England are heavily
differentiated by age, disability, ethnicity, and gender, but
also by geography and socio-economic group. We will ensure that
our policies, collectively and individually, act to narrow gaps
in attainment and participation where these gaps are detrimental
to social justice and economic success." Equality and
Diversity section in implementation plan.
5. In our evidence, we set out some of the
key equality challenges, the extent to which current implementation
arrangements for skills and progression opportunities will be
delivered for individuals and groups identified, and suggest where
additional actions are needed to catch those falling through the
implementation "gaps".
ASSESSING THE
EQUALITY IMPACT
6. The Skills Strategy Equality Impact Assessment
(EIA) identified a risk that existing inequalities will not be
reduced by a one size fits all approach, particularly for people
who experience multiple disadvantage. It recognised that other
vulnerable groups, while not covered by equality legislation,
may also experience disadvantage in terms of skills and employment
and ought to be able to benefit from the Skills Strategy.
7. The EIA identified groups affected by
multiple or other disadvantage as including:
— part-time and temporary workers
— people with caring responsibilities,
— women in certain communities, particularly
of Bangladeshi or Pakistani heritage
— people on welfare benefits, especially
incapacity benefits as a result of mental health problems
— people over the age of 50
— people employed in businesses lukewarm
to training
— migrants especially from EU accession
countries and/or with English language needs
— offenders and ex-offenders
— young people not in education, employment
or training (NEET)
— adult with literacy levels at or
below entry level 2
8. The EIA explained that some of the most
serious inequalities are long standing and are affected by a wide
range of factors which can not be fully addressed by the Skills
Strategy on its own. "Nor can they be removed overnight.
These include deep-seated patterns of gender segregation throughout
the labour market, and high levels of unemployment amongst disabled
people and certain ethnic minority communities."
9. It also identified that data that is
collected often gives a broad picture but does not capture the
finer-grained distinctions that can affect equality and diversity.
10. It is therefore disappointing that despite
recognising the data limitations, and the persistent and wider
challenges of skills inequality, the Leitch implementation plans
include no equality strategy or action plan to focus skills initiatives
on those most in need.
11. We recommend that as a matter of urgency
an equality impact assessment should be made available for the
Leitch implementation arrangements and new delivery initiatives
for skills. We also recommend that the evidence in the Skills
Strategy EIA and our own evidence to this Select Committee raises
sufficient concerns about the impact of initiatives on disadvantaged
groups to warrant the development of a separate equality strategy
and action plan. (For more information on the skills issues and
challenges for particular groups, please see annex 1).
THE IMPACT
OF LEITCH
IMPLEMENTATION INITIATIVES
12. Raising Expectations: enabling the
system to deliver (the Department for Innovation, Universities
and Skills and Department for Children, Schools and Families consultation
document), regards the advent of Skills Accounts and the growth
of Train to Gain as heralding a radically different model of organising
the skills system, where the role of government is to make sure
customers are well-informed and supported so that their demand
for learning leads supply.
13. The Commission is concerned about how
this demand-led system will serve to support those currently deficient
in skills, the hard-to-reach, and those at the margins who have
failed to make—or be heard in—demands for skills acquisition
and progression opportunities to date.
Employers
14. For example, employers will be responsible
for the skills of those in work (approximately 29 million people
). However, evidence to date suggests that the delivery of skills
by employers has not been a major driving force in tackling disadvantage
and inequality.
— Evidence shows that employers have
very negative attitudes to training the over 40s.
— Small employers (employing more than
58% of the private sector workforce and 12 million people) are
less likely to train, as is the service sector—both of which
are most likely to employ low-paid workers, dominated by women
and ethnic minority workers.
15. Articulating the training and progression
needs of workers and those returning to the labour market —including
those trapped in low-skilled jobs and under-using their skills
-and the pay-back to employers, needs to be a key focus of discussions
between skills brokers and employers and should inform the delivery
plans of all the partners to work-based training. Currently there
is little evidence to show that this is happening.
16. We would also like to see more emphasis
on sectoral initiatives, with Sector Skills Councils (SSCs) and
employers, particularly where there are skills shortages, targeting
low-skilled and under-represented groups for training. Also, different
regions face different demographic challenges so geographically-based
initiatives should be created through Local Employment partnerships
and Forums.
17. Train to Gain, because of its focus
on low-skilled people, and employer support, has the important
potential to engage employers and reduce inequalities. A key area
of concern at the end of the precursor Employer Training Pilots
(ETPs) was disability, given the low take-up of only 5% against
a background population of 12%.
18. This data raises questions about results
for other groups, even for those where take up was a closer match
to the background population. For example, we know that the ETPs
were regarded as beneficial to women, but in fact, training had
no impact on job segregation. It is therefore important to carry
out further analysis against the proportion of low-skilled people
in the background population. We are pleased to note that the
LSC (or the new Skills Funding Agency) with responsibility for
planning and implementing the Train to Gain service will be working
with its partners, including Sector Skills Councils and Regional
Development Agencies, to ensure that all information on the programme
is carefully monitored, to check that all learners and potential
learners are benefiting, particularly those affected by multiple
disadvantage. We look forward to seeing this data.
19. In addition, the Train to Gain brief
should be extended to give funding and brokerage support to employers
for skills training for different groups at different levels to
secure progression and best use of employees, not just skilling
at levels for current roles. Where union learning reps are working
with employers to draw up action plans for delivering the pledge,
we would like to see an explicit focus on skills proposals for
all workers at all levels, with targets for groups under-represented.
Those not in work or on welfare
20. Public policy focuses on those in work
(approx 29 million) or those on welfare (approx 5 million). In
addition, there are approximately 4 million people neither working
or on benefits—but this group, silent rather than vocal
in their skills demands— is the hardest to reach and potentially
the most in need. The make-up of this group, their skills and
work potential, barriers and needs, should be identified and directly
addressed in delivery arrangements. This group will include, for
example, women taking time out for caring, Bangladeshi women,
and older people.
21. We do have concerns about the extent
to which the new adult careers service and advancement agency,
and Skills Accounts, will capture the voice and potential of this
silent group and create appropriate arrangements for securing
skills and progression throughout the lifecycle. We know that
within the resources available for the universal adult careers
service, more intensive support face to face will be targeted
on particular groups such as benefit recipients, the low-skilled,
those cycling between welfare and work, and others at key transition
points in their careers. The service has to recognise that many
people face multiple barriers to re-entering work, gaining new
skills and better jobs and the extent to which the arrangements
will permit outreach and tailor-made solutions is unclear, particularly
for those not falling clearly into the target groups.
Skills across the lifecycle
22. The link between skills and employment
is vital and should be developed further, with a lifecycle approach
delivered through skills accounts and the adult careers/advancement
agency to support acquisition and use of skills. Focusing funding
at front-loading young people with skills is important, but life-cycle-sensitive
skills initiatives need to be developed, recognising the importance
of re-skilling so that people are able to move in and out of work
without losing ground, to stay longer in work, improving individual
prosperity and contributing higher levels of productivity to the
fast-changing global economy.
23. We welcome the proposal for further
work between DIUS and the Department for Work and Pensions (DWP)
to define a clear prospectus for Jobcentre Plus (JCP) and the
careers service which acknowledges the range and nature of the
problems people face and which recognises the different customer
journeys which will be undertaken according to need. We look forward
to seeing more detail of this.
Advancement agencies
24. We also look forward to more information
about the role of the advancement agencies. As well as tackling
persistent movement in and out of low level work, advancement
agencies provide an exciting new opportunity to identify ways
of securing progression for all groups.
TARGETING AND
ENTITLEMENTS
25. The specific and urgent priority for
skills delivery is identified as tackling the skills and employment
needs of those out of work or who have low skills, with entitlement
to a first full level 2 qualification. While we recognise the
need for this entitlement, we are concerned that the importance
of enabling people who have been out of the labour market to re-fresh
outdated skills to improve their employability is not recognised
through current proposals. We suggest that consideration should
be given to extending the entitlement to support lifelong learning
and re-training in skills that have currency in the labour market
for people to support effective re-entry and progression into
sustainable work.
26. Similarly, we have concerns about the
impact on many adult workers of entitlement to level 3 training
only for first level 3 and for those up to age 25. We note that
women currently are under-represented in those holding level 3
qualifications but over-represented in those at level 2. The importance
of creating progression routeways suggests that more consideration
should be given to targeting the level 3 entitlement more broadly.
27. We welcome the Women in London, level
3 Train to Gain pilots as an example of this. These are aimed
at supporting women to qualify at level 3 in occupational areas
where they are currently under-represented, and place an emphasis
on engaging women in ethnic minority communities. Early data indicates
that 15.5% of learners were from such communities, with the highest
single proportion of these (5.6%) being of South Asian heritage.
We are also aware of the successful Ambition-energy scheme for
women and recommend that consideration is given to how these successful
skills programmes can be rolled out more widely.
28. National Skills Academies (NSA) are
expected to apply high standards on equality and diversity in
all their provision. NSAs will be evaluated after an initial period
of operation, in early 2008. The evaluation will determine whether
the NSA programme or a specific NSA has promoted equality and
diversity, and attraction of under-represented groups in the sector
into provision."This will include attention to issues relating
to age, disability, ethnicity and gender. NSAs will be expected
to record data relating to equality as part of their on-going
management information. We look forward to this equality evaluation
and we would like to see NSAs having equality targets for participation
and progression.
29. The Commission welcomes the entitlement
to apprenticeships, recognising the benefits that quality apprenticeship
programmes can bring. However women are more likely to participate
in Apprenticeships at level 2, and men are more likely to participate
in Advanced Apprenticeships at level 3. This is partly because
the sectors dominated by women are less likely to offer apprenticeships
at level 3. Latest figures show that of the 100,000 young people
on Advanced Apprenticeships in England, just 30 per cent are female.
The EHRC has recently responded to the Review of Apprenticeships.
In particular, we have highlighted the need to address overt gender
segregation and differential pay rates across sectors, creating
a significant gender pay gap. We have also provided data on wider
diversity issues.
30. We also welcome the new Commission for
Employment and Skills and recommend that delivery of equality
and diversity should be a key strand of its remit. In addition
to reporting on progress towards skills ambitions across all groups,
the new Commission should monitor equality impact, best use of
human capital, return to education and skills, and matching of
skills to jobs.
UNDER-USE
OF SKILLS
31. The National Adults Learning Survey
points to the need to extend flexibility of training provision
and to extend support to help people to overcome wider barriers
currently limiting advancement in their careers, such as lack
of childcare. Trends in average earnings over a lifetime show
that women often fail to progress, and lack of skills is not necessarily
the barrier. However, Leitch implementation plans and funding
arrangements do little to address redundant skills and under-use
of skills.
32. Recent EOC research found significant
evidence that education and skills investment was leaking out
of the system with women particularly trading down and under-using
skills. Irrespective of qualification levels and career aspirations,
there is a mismatch between the quality of jobs people hold and
their qualifications. This is a key feature of the labour market,
particularly for women:
— 4 out of 5 part-time workers are
working below their potential.
— 12% of women with level 4 qualifications
or above are working in the bottom 25% jobs
— The proportion of graduates in good
quality jobs has decreased significantly from 72% in 1995 to 54%
in 2005.
— 6.5 million people are working in
jobs below their skills levels or outside the labour market because
they are unable to find sufficient flexibility in work.
— people with level 3 and above qualifications
have no source of guidance or support to place them in jobs commensurate
with their skills. HEIs don't provide careers advice and support
beyond the present cohort—former graduates have no where
to go for careers advice.
33. An important part of the progression
agenda is recognition that acquiring skills and moving up the
skills ladder needs to be supported by opportunity to re-skill
for opportunities in the changing labour market and to use skills
at the right level, to deliver the pay return and therefore the
increase in social mobility. The role of new flexible ways of
working in translating skills acquisition into use and reward
need to be much higher on the agenda for employers, the new advancement
agency, skills brokers and JCP. Other barriers to progression
need to be identified and addressed in delivery initiatives. These
include prejudice, discrimination, stereotyping, lack of flexibility,
and childcare.
April 2008
Annex 1
Skills issues and challenges for particular groups
Ethnic minority workers
People from different backgrounds and communities
do not all enter the labour market with similar levels of qualifications.
Attainment is lowest amongst young men of African-Caribbean heritage—in
summer 2005 only 21% obtained five A*-C passes, compared with
a national averages for young men of over 38%, and for all young
people of 43%.
People from South Asian, black and other ethnic
minority backgrounds are almost twice as likely to be unemployed
as the national average. The employment rate amongst white people
is 77%. For people of Indian and African-Caribbean heritage it
is 70% and 69% respectively. For those of Pakistani heritage it
is 44% and for those of Bangladeshi heritage 39%.
The greater percentage of people from ethnic
minority backgrounds in post-16 education is not reflected in
the numbers that enter employment or government-sponsored training:
only 4% are enrolled in work-based training or apprenticeships
as compared with 10% for white young people.
Skills challenges
— reducing and removing inequalities
in success rates between different communities
— increasing the participation of people
from ethnic minority communities in work-based learning
— ensuring that issues of religious
identity, faith, values and affiliation are taken into account
in race equality policies and projects
— enhancing the quality and coverage
of statistical information, for example by providing breakdowns
by region and gender as well as ethnicity.
Older workers
The over 40s make up 50% of the working age
population and 65% of those without level 2 qualifications.
Skills challenges
— reversing the decline in the numbers
of adults in their 40s, 50s and 60s taking part in training and
re-skilling, particularly to support change and transition in
mid- and later career
— challenging and removing prejudice
against providing training for older workers
— enabling older people to update their
skills in order to remain in, or return to, the labour market
— establishing ICT skills as a major
priority for development and investment by employers and funding
agencies, to support retention and recruitment of older people
— developing forms of skills training
particularly appropriate in the late-working and early-retirement
ages
— increasing the number of older people
in the workforce as the pool of younger workers declines
Disabled people
Disabled people account for a third of all those
without formal qualifications. 21% of disabled people aged 16-24
have no qualifications, compared with 9% of non-disabled people
of the same age. Only 8% of disabled people have a degree-level
qualification, compared with 17% of non-disabled people.
Participation in learning in the last three
years is lower amongst those who are disabled (73%) than among
those who are not (84%), although the proportion of disabled people
participating in learning has increased.
Only 44% of disabled people are economically
active compared with 79% of non-disabled people.
Skills challenges
— increasing the meaningful participation
of disabled people in higher and further education
— ensuring that disabled people are
more actively involved in the design, development, review and
delivery of policies that affect them
— ensuring that capital funding covers
reasonable adjustments and specialist support services to enable
access to learning for disabled learners
— developing information, advice and
guidance (IAG) for disabled people, including those with learning
difficulties, so that they are fully aware of learning, career
and work opportunities, and of funding and assistance available
to them
— addressing low levels of awareness
and understanding of disability issues amongst the general public
and amongst employers, employees and providers of skills training,
Women and men
Men are under-represented in nearly all adult
learning programmes. Although men may need more encouragement
to learn at Level 2 and Level 3, overall they still have higher
qualification levels than women. Amongst people of working age,
women are slightly more likely than men to be qualified to Level
4 and above (27% of women, 26% of men) and women are also more
likely to be qualified to Level 2 (23% of women, 21% of men).
Men are much more likely than women to be qualified to Level 3
(23% of men, 16% of women) and women are more likely than men
to have no qualification, or qualifications below Level 2 (33%
women, 29% men).
Fewer than half of female graduates are now
in high-level jobs and the trend is getting worse (45% qualified
to Level 4 compared with 65% 10 years ago).
Women generally work in a narrow range of lower-paying
occupations, mainly those available part-time, that do not make
the best use of their skills.
Skills Challenges
— closing the gender gap in pay
— removing barriers to women working
in occupations traditionally done by men
— addressing the educational underperformance
of young men, particularly those in low socio-economic status
categories
— addressing the under-representation
of women in science (including computer science), engineering,
construction and technology (SECT), as learners, teachers, researchers
and practitioners, and on SECT-related public bodies
— improving the participation of young
women in government training schemes such as apprenticeships,
particularly in construction and engineering
— improving the information base, for
example by collecting and analysing data which cross-tabulates
gender with age, disability and ethnicity.
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