Coalition for Racial Equality and Rights - anti-racist policy making: review summary

Anti-Racist Principles for Effective Practice

This section explores considerations for future policy from an anti-racist perspective.

Structural racism describes how racism is created and maintained throughout the structures of society, at personal, social and institutional levels. In nations such as Scotland, an unspoken 'racial contract' that sites power firmly within the hands of the white majority ethnic community pervades these structures. Anti-racism aims to disrupt this racial contract. It can be seen as the theoretical framework underpinning practical action to tackle structural racism.

Anti-racist actions are more likely to be effective because anti-racism focuses on creating change. An anti-racist action proactively and demonstrably reduces racial inequalities, discrimination or racism.

Actions under previous race equality policy have tended not to lead to demonstrable change. They were often broadly worded, bureaucratic or without a clear purpose.

Actions designed from an anti-racist perspective might be expected to:

• Express the change to be achieved in the lives of people from minority ethnic communities
• Feature milestones, targets or similar specified goals
• Clearly link to progress indicators, ideally in numeric / percentage based terms, which can be robustly measured through data or ongoing research
• Reflect anti-racist principles

Anti-racist principles which may have particular relevance to policy making in Scotland were identified in the review:

• Redressing power hierarchies inherent in current approaches to policy development, including the impact of lack of representation of minority ethnic people in positions of influence and decision making roles
• Correcting economic, political and social imbalances created by white privilege and entrenched racial inequalities through positive action and other forms of targeted action
• Implementing structural and systemic solutions to racial inequalities – changing policy and practice, as opposed to 'sticking plaster' approaches which treat the effects of structural racism rather than its origins
• Avoiding the deficit model which downplays structural racism in favour of explanations related to personal capacity, culturally specific attitudes and behaviours or individual choices (often replicating racist stereotypes and/or minimising the role of racism in creating and maintaining inequalities)
• Rights based approaches which recognise that inaction on racism and racial inequalities breaches the rights of minority ethnic people; other potential imperatives for action which may be more palatable and avoid disrupting the racial contract, such as 'the business case' for equality, are counterproductive
• Intersectional approaches particularly recognising the specific inequalities facing minority ethnic women^[3]
• Overcoming discomfort or reticence that policy makers may have around frank discussion of race and racism, and other manifestations of white fragility which could impact policy making
• Policy making based on robust evidence about the nature and prevalence of racial inequalities and racism, as well as 'what works' to create change
• Effective, meaningful involvement of minority ethnic people and organisations with tangible impacts on policy development
• Building capacity on race equality and anti-racism, with recognition that it is not the responsibility of minority ethnic people to 'educate' policy makers
• Creating interest convergence by providing strong imperatives for policy makers to come together with race equality stakeholders and identify solutions
• Prioritising effective, measurable action to secure race equality over and above the optics of ethos and rhetoric on race equality

The final point is particularly important. Although there is no universally agreed definition of anti-racism, the main point of common understanding is that it requires action against personal, social and institutional racism. Inaction is, in itself, a policy making decision. Policy makers wield power not just through what they do, but through what they choose not to do.^[4]

The review identified a range of factors needed to create effective policy on race equality: sustainability and continuity; effective solutions; capacity building and leadership; involvement and partnership working; strategic planning and implementation; and meaningful progress reporting.

Sustainability and continuity have been notably absent in Scotland's approach to making policy on race equality. The nature of racial inequality in Scotland has remained fairly static over the past twenty years,^[5] but lack of evaluation means there's insufficient evidence to determine why previous approaches failed. Progress reporting focused on stating that the proposed actions have been taken, so nothing can be learned about progress towards the end goals.

Weaknesses in understanding 'what works' create a grave risk of repeating ineffective practice. This risk must be mitigated by:

• Building stronger evaluation mechanisms into strategy during the development process (the Equality and Human Rights Commission's principles for meaningful evaluation of anti-prejudice work, developed by CRER, are useful for planning evaluation of any aspects of race equality policy)^[6]
• Sharing the results of evaluation, with equal value placed on evidence of what works and what does not work; seeing the latter as a learning process rather than a 'failure'
• Benchmarking exercises to gather baseline data on inequalities, from sources which can be regularly revisited through progress monitoring to identify change over time in relation to commitments and actions
• Measures to ensure continuity of implementation within teams and directorates, especially where key staff move or leave their position
• Making the best use of the evidence which can be gathered, while also addressing gaps

Effective solutions need to be identified in order for race equality actions to work. The questions "will it work?", "how will it work?" and "how will we know if it worked?" should be omnipresent in the process of identifying solutions.

There is a need to establish a clear link between race equality strategies' objectives and the most effective mechanisms for delivering them. In addition to targeted strategies, race equality must be mainstreamed into all areas of policy. In the past, the tendency has been to 'bolt on' a generic commitment to 'consider race implications', which is often not carried out.

Whether in targeted or mainstreamed, the process of identifying solutions needs to be structured and logical. Outcomes based approaches that work backwards from the goal to identify viable, meaningful, measurable actions are needed.

Within an outcomes based approach, policy makers need to:

• Specify the inequality to be addressed using evidence
• Set outcomes that express the changes we need to see in people's lives
• Identify reasonable assumptions about what will work to achieve these
• Develop SMART actions
• Identify with certainty where these best fit into the policy landscape

The review suggests that logic modelling is a useful tool for evidence based policy. Evidence based policy is the foundation of effective race equality work. It isn't possible to find the right solutions without using evidence. However, the review found that published commitments to seek more evidence or to consider evidence are not always implemented, and rarely lead to action.

The review findings highlighted the need to:

• Bring in evidence before the policy making process begins in earnest
• Draw on a wide range of evidence, from previous evaluations where possible, from quantitative and qualitative data, and from involvement
• Prioritise different pieces of evidence according to their relevance and validity
• Ensure continuity of availability of research and involvement results to avoid 'reinventing the wheel' and creating consultation fatigue
• Tackle gaps in data disaggregated by ethnicity, particularly at a granular level (i.e. looking at individual ethnicity categories)

Involvement and partnership working are important to identify appropriate solutions, and can create a valuable sense of ownership of actions if the right partners are around the table. Stakeholder involvement can be one way of achieving this, however internal staff networks and advisory groups can also be called upon.

Civil servants should always be receptive to input from stakeholders, but need to assess which 'asks' should be prioritised for action in light of the wider evidence and the extent to which effective action can be taken by Government.

Potential ways to strengthen approaches to involvement include:

• Working with stakeholders to develop shared principles on the involvement of minority ethnic communities and those who represent their interests, including around co-production and collaborative working
• Reviewing the outcomes of previous involvement (with reference to the National Standards for Community Involvement) in order to address weaknesses in practice which may be limiting its influence
• As far as possible, building evidence based and rights based consensus on the underlying causes of racial inequality in order to limit the influence of factors which can damage the policy process (e.g. racial stereotypes, internalized racism and the 'deficit model' which suggests behaviours of minority ethnic groups are the source of inequality)

Some key factors were also identified regarding steering groups / working groups:

• Members of the group all need to have sufficient experience and knowledge in the specific policy area (avoiding 'involvement for involvement's sake')
• Group members need a shared understanding to work from, with mutually agreed principles, terms of reference and a robust framework for designing solutions from the beginning
• The group needs to have enough authority to ensure that its work is unimpeded and that its recommendations are implemented
• Groups must adopt the most effective solutions, so the decision making process must include rejecting suggestions that replicate ineffective approaches, are poorly evidenced, are vague or are unfeasible

National agencies are one of the main partners involved in race equality policy. The review highlighted that Scottish Government may want to consider:

• Working with the Equality and Human Rights Commission to strengthen enforcement of the Scottish specific public sector equality duties
• Assisting national agencies to 'join up' their approaches to capacity building
• Identifying levers to motivate national agencies to increase their focus on race equality (e.g. audit and inspection, outcomes agreements, funding requirements)
• Building on the work begun through the 2021 Race and Employment Summit and associated joint statement committing to tackling institutional racism

Capacity building and leadership have been recurring themes across twenty years of race equality policy. The review makes it clear that capacity building cannot be as simple as providing a training course. Training courses are only one of many ways to build capacity and embed race equality and anti-racist principles in the day to day work of civil servants across the board. To support better practice in training, however, CRER has developed a set of anti-racist training standards.

Some key areas to address through capacity building include:

• Ensuring a common understanding of structural racism and how it operates on personal, social and institutional levels
• Building confidence to have safe, productive discussions on race and racism
• Developing skills to interpret and prioritise evidence from an anti-racist perspective
• Providing tools for effective planning and implementation

Specific opportunities may be needed for those leading on involvement and partnership working to equip them to carry this out appropriately.

Capacity building needs to be accompanied by strong leadership; civil servants operate within a hierarchical environment where certainty on priorities and ethos is needed. The review found that weaknesses in leadership often caused actions to be poorly implemented, poorly resourced and poorly reported on.

Responsibility for achieving targets and milestones must belong to senior staff in positions of influence and power. Where implementation falters, it must be their responsibility to redress this.

To make race equality policy effective, leaders need to:

• Mainstream race equality actions into the work streams of the teams responsible for delivering them and ensure this is maintained over time
• Use their influence to engender action and create motivation
• Ensure consistent progress monitoring takes place and is recorded
• Uphold mechanisms for scrutiny, transparency and accountability

Strategic planning and implementation processes need to set out coherent, consistent, effective approaches to delivering solutions. The review found that an often cluttered, values-driven (as opposed to outcomes-driven) race equality policy environment had created difficulties at various points in time.

An effective strategic plan on race equality would have the following qualities:

• Synergy across policy areas, balancing targeted and mainstreamed approaches
• Well-constructed outcomes and actions with performance indicators, targets and milestones, timescales and responsibilities
• Mechanisms for implementation, evaluation, monitoring and progress reporting which are embedded in departmental work plans and/or objectives
• Robust accountability, transparency and scrutiny arrangements

Strengthening implementation is also crucial for race equality policy. Examples of practice to strengthen implementation highlighted in the review included:

• Proactive leadership on implementation at all levels of the organisation
• Mandatory personal and/or departmental objectives
• Scrutiny mechanisms, both internal and including external stakeholders
• Clear allocation of responsibility, including reallocation where staff move
• Regular progress monitoring and reporting at all levels of implementation

Progress reporting mechanisms for race equality strategies have varied widely over the years. All previous approaches to progress monitoring have shared an intrinsic weakness; the focus on reporting outputs rather than outcomes. From an anti-racist perspective, there is little value in this approach.

The review identified improvements to progress reporting practices which Scottish Government may want to consider:

• Reporting on each action individually and clearly
• Demonstrating change over time in each of the strategy's outcomes
• Where a commitment has not been met, explaining why and what else is being done to address the relevant inequalities
• Developing annual cycles of monitoring and reporting