Business plan 2024 to 2025

2024–2025 will be the final year of delivery against our current strategic plan. We have developed a plan that builds on our work to date, reflects our ambition and prepares for our next strategic plan period.

Strategic context

In March 2022, we published our Strategic Plan for 2022–25. In that strategic plan we identified six areas of external focus and laid out our commitment to improving our own organisation. These are:

• equality in a changing workplace
• equality for children and young people
• upholding rights and equality in health and social care
• addressing the equality and human rights impact of digital services and artificial intelligence
• fostering good relations and promoting respect between groups
• ensuring an effective legal framework to protect equality and human rights

Through these areas of focus we have continued to deliver  our commitments across our regulatory framework. For equality in a changing workplace, we launched our menopause guidance, designed to inform workplaces about how they can support women. We have also ensured compliance with gender pay gap reporting, doing so in record time. We influenced the development of legislation to strengthen rights protections, as with the development and adoption of the Worker Protection (amendment to Equality Act 2010) Act and provided guidance to organisations, including launching our sexual harassment toolkit.

For children and young people, we have built on the work from our 2021 Restraint Inquiry. We responded to a UK Government call for evidence to help them meet their commitment to reducing the use of restraint in schools. We also intervened in the case of University of Bristol v Abrahart to clarify the law around reasonable adjustments and to tackle disability discrimination against university students. In our health and social care programme, we have worked with Local Authorities and health and social care organisations across Britain to ensure compliance with the Public Sector Equality Duty (PSED).

For AI and digital, we responded to the UK government’s white paper on AI Regulation, and we have been working to develop scope and options for how we consider AI in recruitment and the use of facial recognition technology. We will continue to focus on these projects in 2024-25. For fostering good relations, we advised relevant government departments about the development of guidance on issues relating to sex and gender. We also established positive working relationships with partner organisations to influence the development of guidance relating to freedom of expression. At a time of increasing political debate, we have intervened to offer guidance to other public authorities about the balance of human rights considerations. 

Our effective legal framework programme considers our work to develop evidence, deliver our human rights responsibilities and our strategic litigation to challenge serious and systemic issues. In November 2023 we provided authoritative evidence on the state of equality and human rights across Great Britain with our Equality and Human Rights Monitor, as well as partner publications for Scotland and Wales. We advised governments and parliaments on legislative proposals that affect the equality and human rights legal framework, such as the Safety of Rwanda (Asylum and Immigration) Bill. 

We took enforcement action where necessary, including through section 23 agreements with McDonald’s Restaurants Limited and IKEA UK. We have investigated serious equality breaches by Pontins holiday parks. Our February 2024 report achieved the highest engagement we have seen in recent years. We used our litigation powers to intervene and support cases where there are breaches of equality rights, including through our Race Legal Support Fund. We expanded our initial commitment and helped over 45 individuals achieve justice. We also intervened in high profile strategic litigation, such as Manjang v Uber Eats, helping raise the profile of the issues we regulate and securing positive outcomes for people.

We delivered against our international and human rights responsibilities, publishing reports relating to government compliance with the UN Conventions on the Rights of the Child, the Rights of Persons with Disabilities, the International Covenant on Economic, Social and Cultural Rights and the Council of Europe Convention on preventing and combating violence against women and domestic violence.

Internally, we continued to build our commission and improve our office estate. We developed our ability to work in a hybrid way, while encouraging improved collaboration through greater attendance at our office locations. We strengthened our workforce to maximise our delivery.

We will share more of our impact over the course of 2023–24 through our Annual Report and Accounts.

In 2024–25, we will focus on achieving the strategic goals laid out in our 2022–25 Strategic Plan. We will complete the delivery of key projects, evaluate what we have achieved and continue our internal transformation to be a more agile and effective regulator. We will also look ahead to the 2025–28 strategic plan period and beyond, scoping future work and preparing for delivery against a backdrop of diminishing resources.

Our business plan for 2024–25 describes the major projects we plan to deliver in the coming year. This includes robust corporate and team plans to ensure the capacity to deliver on this planned work. We will also be ready and able to respond to issues and opportunities that require our attention in 2024–25. Our aim is to propose activity that is:

• achievable
• realistic
• likely to achieve real-world system and behaviour change

We will continue to deliver against the goal we outlined in our strategic plan, to focus our resources where we can make a real, lasting, positive difference to the lives of individuals across Britain.

Alongside our planned work, we will play a key role in influencing the UK, Scottish and Welsh Governments on equality and UK and Welsh Governments on human rights issues. Our aim is to prevent issues arising by ensuring that policy and legislation protects and promotes equality and human rights. By using data and evidence effectively, we can make the most of opportunities to advise and influence.

Priority themes

For our 2024–25 business plan, we will continue to deliver against our six external priority areas and the internal improvement programme. We have introduced a thematic approach to our work to maximise opportunities for collaboration between programmes. 

We have longstanding expertise and impact as a regulator in tackling inequalities in a changing workplace. This year we will lead a campaign to prepare employers for the new duties created by the Worker Protection (Amendment of Equality Act 2010) Act 2023 (the 2023 Act) including by updating and consulting on our sexual harassment technical guidance. We will also consider where regulatory action needs to be taken to tackle breaches when the new regulations come into place.

We will evaluate our Preventing Sexual Harassment at Work Toolkit for the hospitality sector and consider how this might be adapted for other sectors. We will also continue to identify where there are breaches of equality duties in the workplace and take enforcement and litigation action where necessary and appropriate, including in relation to the new duties in the 2023 Act.

Emerging from our work in the equality in a changing workplace area of focus, this strategic programme will tackle discrimination, harassment and victimisation in the workplaces of fire services, police and armed forces. It will support both the employers and regulators of uniformed services to start delivering changes designed to address widely discussed concerns. 2024–25 activity will include:

• publishing guidance and delivering training on the collection and effective use of equality data to inform workplace equality objectives and actions
• delivering training about the collection of workforce equality data
• establishing effective partnerships with other regulators, inspectorates and ombuds (RIOs)  
• working with organisations to solve problems and comply with best practice
• enforcement action, if and where needed

Artificial intelligence (AI) is a fast-moving area. While there are big opportunities, there are also significant risks of discrimination. Government and others are increasingly looking to us for support. The AI Regulation white paper places significant expectations on regulators. We will continue to develop our approach to regulation in this space, improving our understanding, engaging with other regulators and making use of our powers.

In 2024–25 we will focus on our role in reducing and preventing digital exclusion, particularly around:

• older and disabled people accessing local services
• the use of AI in recruitment practices
• developing solutions to address bias and discrimination in AI systems
• police use of facial recognition technology 

We are concerned that, once the use of facial recognition technology becomes normalised, it will not be possible to move away from it, both in policing and elsewhere. We will also partner with the Centre for Data, Ethics and Innovation (CDEI) on the fairness innovation challenge to develop tools for tackling algorithmic bias and discrimination.

For children and young people, we continue to be concerned about:

• the use of restraint in institutions
• issues relating to exclusions

We will continue to provide advice on the development of policy and legislation for these issues, taking enforcement action where necessary.

We will continue to draw on the learning from our Restraint Inquiry by engaging with governments on behaviour and restraint policies.

We will also look for opportunities to improve compliance with the PSED.

While mental health reform in England has been paused, we will continue to respond to opportunities to intervene in Scotland and at more local levels and prepare for the likely inclusion of a mental health bill in a future legislative agenda. We will continue to consider responsive opportunities to protect human rights in care and ensuring equality in care environments, particularly through:

• enforcement of the PSED in the health and social care sectors
• monitoring for abuses of human rights in health and social care settings that require a regulatory intervention

We will seek to influence the design and implementation of national care services in Scotland and Wales to ensure that equality considerations are embedded from the outset.

Our guidance is an essential element of our support to both public and private sector organisations to ensure that they adhere to the requirements of the Equality Act 2010 and human rights obligations. Our codes and guidance are a key way to influence and support organisations. This should result in fewer breaches and less need for intervention through compliance, enforcement and litigation powers and levers.

In 2024–25 we will review, consult on and refine our Services Code of Practice. We will also review more generally our wider guidance, ensuring that we have efficient and forward-looking systems to manage appropriate updates to our guidance. We will update our schools’ guidance in Wales relating to the Welsh Government’s transgender guidance. When public bodies do issue guidance, we will seek to ensure it is consistent with Equality Act 2010 and Human Rights obligations.

We will continue to apply our legal strategies to challenge serious or systemic breaches of the law. Our legal strategies represent the areas of litigation we intend to focus on throughout the life of our current strategic plan. More detail about the types of cases we are interested in exploring for 2024–25 can be read here. We will also consider challenging serious or systemic breaches of equality or human rights law in any area of our responsibility. This will be guided by the criteria set out in our policy to decide whether and what action to take.

The PSED requires public authorities and organisations carrying out public functions to consider how they can improve society and promote equality in every aspect of their day-to-day business. This year, our focus is on strengthening the use of the PSED in health and social care settings, including Integrated Care Boards in England and through sector regulators.

Our aim is to build better community-based services. We will also build on our work to strengthen the role of the PSED in the use of AI and in digital provision. We will continue our work to improve compliance with the PSED in the development of policy for children and young people in England.

In Wales, we will be monitoring public authorities’ compliance with setting their new equality objectives. We will check that they are focused on addressing the most persistent inequalities. We will also be working to increase schools’ compliance with the PSED. Finally, we will develop and publish a toolkit and new guidance to support public bodies in executing their duties.

Our duty to foster good relations underpins all of our work and communications. We will take opportunities to respond where we identify divisive public discussion, amplified by the media and social media, which reinforces prejudice or divides communities.

In 2024–25 our focus will be on upholding the right to freedom of speech. We will respond to any legislative changes from the Higher Education (Freedom of Speech) Act 2023. This includes engagement with the Office for Students (OfS) about the issue of freedom of speech in Higher Education settings.

As a National Human Rights Institution (NHRI), we promote awareness, understanding and protection of human rights, encouraging public bodies in England and Wales to follow the Human Rights Act. We protect those most at risk of human rights abuses and monitor human rights, reporting our findings to the UK Government and the United Nations.

In 2024–25 we will make improvements to our Human Rights Tracker with a new methodology and website. We will also continue to report in response to UN treaties as required.

We will strengthen our internal capacity to evaluate our work robustly and routinely. We will test our evaluation methodologies against specific work delivered over the course of 2022–25. We will develop a formal evaluation strategy to support this and make sure that this helps to develop future activities.

We will complete delivery of our Race Legal Support Scheme and evaluate the impact of this scheme and similar schemes we have previously delivered. The outcome of this evaluation will inform the development of future legal support schemes.

We will undertake work to understand how our gender pay gap reporting work is performing, reflect on first principles of pay transparency and further strengthen our approaches.

The Socio-economic Duty (SED) has been in place in Scotland since 2018 and in Wales since 2021. We will work to understand how the duty has been implemented and what any early impact might look like.

We will develop our 2025–28 Strategic Plan, informed by the evidence from our Equality and Human Rights Monitor and public consultation.

We will further strengthen our approach as an evidence-led regulator, building on the expertise used to develop our Equality and Human Rights Monitor. We will build data and evidence capability and capacity in our organisation to understand how we can best focus our limited resources on issues that will achieve the greatest systemic and behavioural shifts.

Our Building our Commission programme was developed to improve how we work as an organisation. We will continue to deliver against this programme with a reduced number of priority activities, which are:

• structure
• working practice
• knowledge

We will also:

• strengthen our governance
• look at the systems we use for our day-to-day work, to help us to find better and more efficient ways of working and delivering our projects
• conduct a fundamental review of our estates and locations strategy

A primary area of focus will be the continued delivery of our data and evidence strategy. Modern regulators need a solid evidence base and the ability to analyse it to be able to act effectively. In 2024–25 we will strengthen our internal capability and capacity on data and evidence, developing our Centre for Expertise, ensuring that all functions routinely use best practice in deploying analysis in all parts of our regulatory model.

We will continue to develop our people, building our leadership and management capacity to further professionalise our organisation. We will strengthen our core skills relating to the use of evidence in decision-making and better understanding the effects and impact of what we do.

We will continue to support our people to work effectively in a hybrid way through improvements across our estates and locations. We will complete our work to update and embed our ways of working.