Equality and diversity policy

What the law protects

The Equality Act protects nine characteristics. All nine are listed, because a list that stops at the obvious ones teaches people that the rest do not count.

• Age
• Disability
• Gender reassignment
• Marriage and civil partnership
• Pregnancy and maternity
• Race
• Religion or belief
• Sex
• Sexual orientation

Disability includes mental illness, learning disability, autism, long-term physical conditions and conditions that come and go. You do not need a diagnosis, a letter or a benefit award to be disabled for the purposes of the Act, and we will not ask you to prove it before we will talk to you about an adjustment.

Other things are not protected characteristics but matter just as much to how we work: whether you have been homeless, whether you have been in prison, whether you have been in care, your immigration status, whether you have children, and whether your income is from benefits. Two of those the law deals with separately — since 1 May 2026 it has been unlawful for a landlord to discriminate against somebody because they have children or because they receive benefits.

What we must not do

Part 4 covers the management and letting of premises; Part 3 covers services. Both apply to us. It is unlawful for us to:

Discriminate directly

Treat you worse than somebody else because of a protected characteristic.

Discriminate indirectly

Apply a rule that looks neutral but puts people who share a characteristic at a disadvantage, where we cannot justify it. A rule that every resident must attend a meeting in person is the ordinary example.

Treat you unfavourably because of something arising from a disability

Unless we can justify it. This is the one most often engaged in housing — where somebody’s behaviour, rent arrears or missed appointments are a consequence of a mental illness or a learning disability. It has its own clause below.

Harass you

Behaviour connected to a protected characteristic that violates your dignity or creates a hostile or degrading environment for you.

Victimise you

Treat you badly because you complained about discrimination, or supported somebody else’s complaint. Complaining is protected, and it will never put your home at risk.

Fail to make a reasonable adjustment

The next clause is about this one.

This applies to the terms we let on, to the services and facilities you get, to how we manage the home, and to eviction. It applies to our contractors when they are in your home, and to our staff.

Reasonable adjustments — what you can ask for

An adjustment is a change we make so that being disabled does not put you at a disadvantage. It is a legal duty, not a favour, and it is anticipatory — we are supposed to have thought about it before you ask.

Things people actually ask for, and get:

• Letters in large print, easy read, braille or audio, or by email rather than post.
• Being contacted by text or letter rather than by phone, or the other way round.
• An interpreter, including British Sign Language, at no cost.
• Longer appointments, or appointments at a time of day that works with medication.
• The same member of staff each time, where somebody finds new people hard.
• A support worker, relative or advocate at every meeting.
• More time to respond to a letter, or a reminder before a deadline.
• A different way of paying rent, or of reporting a repair.
• Being visited at home rather than coming to an office.
• A change to a rule in your agreement, where the rule affects you differently.
• Equipment or an aid that helps you use the home or our service.

How to ask. Tell any member of staff, or use any route on our contact page. You do not have to use the words “reasonable adjustment”, you do not have to put it in writing, and you do not have to explain your diagnosis — telling us what is difficult is enough. Somebody can ask on your behalf.

What we do with it. We record it, so you do not have to ask again every time. We tell you what we have agreed. If we say no, we say so in writing with the reason, and we say what we can do instead. A refusal can be complained about, and our complaints policy applies.

Where a physical change to a building is needed, the law draws a distinction: the duty on a landlord managing premises does not extend to removing or altering a physical feature, while the duty on a service provider does. We are doing both of those jobs at once, and that boundary is not settled. We are not going to use it as a reason to say no without looking. We will tell you what can be done, what cannot, and why — including where the answer is that we lease the building and need the owner’s consent. Where the change is a repair rather than an adjustment — a fault, damp, a failed extractor fan — it goes down the route in our repairs, damp and mould policy, which is faster and costs you nothing.

TBD — who decides. The job title of the person who decides a reasonable adjustment request, and the route for asking for one outside office hours. Roles, not names, and operations has to confirm both.

Disability, behaviour and possession

This is the clause that matters most in supported housing, and it is the one most often missing from a policy like this.

Where somebody’s rent arrears, missed appointments or behaviour are a consequence of a disability — including a mental illness, a learning disability or autism — treating them unfavourably for it is unlawful unless we can justify it as a proportionate means of achieving a legitimate aim.

So, before we take any formal step against a disabled resident, we:

1. Ask whether what is happening arises from a disability.
2. Ask what support or adjustment could deal with it instead.
3. Record whether the step we are proposing is proportionate — what we are trying to achieve, and whether there is a less drastic way of achieving it.
4. Take that assessment into account before deciding, not afterwards to justify it.

A court will ask to see that assessment in any possession claim against a disabled person. So will we, internally, before a claim is issued. Our anti-social behaviour policy applies the same test to behaviour cases.

How allocation and lettings decisions are made

We are not a council and we do not run a housing register. Almost everybody who lives with us arrives by referral — from a local authority, from a charity, from probation, from a hospital or prison discharge team — or by approaching us directly. How the decision works:

1. A referral or an enquiry arrives, with information about what somebody needs.
2. We assess whether we can meet those needs at a particular scheme, and whether it is safe for that person and for the people already living there.
3. We decide, against written criteria, and we record the reason.
4. If we say no, we say why — to the person and to whoever referred them — and we say what would change the answer.

What we do not do. We do not turn people away for having been homeless, having been in prison, having been in care, having children, or being on benefits. We do not ask for a guarantor or rent in advance as a way of screening people out. We do not prefer one nationality, religion or ethnicity to another. Where a scheme is for a particular group — for instance a service for women who have left an abusive home — we record the legal basis for that restriction rather than treating it as obvious.

Saying no is not the same as discriminating, and we will be straight about it. A scheme with shared facilities may not be safe for somebody whose needs it cannot meet, and placing somebody somewhere that will fail them is not kindness. The test is whether the reason is a real one, applied consistently, and written down.

TBD — the written criteria. The written eligibility and referral criteria for each scheme — who it is for, what needs it can and cannot meet, and who decides. A resident refused a place is entitled to be told the criterion they did not meet, and that is impossible until the criteria are written down. Operations owns writing them, scheme by scheme.

If you think a decision was discriminatory, complain. Our complaints policy covers applicants as well as residents.

The public sector equality duty, and why we do not claim it

Section 149 requires public authorities to have due regard to eliminating discrimination, advancing equality of opportunity and fostering good relations. It also catches anybody else who exercises public functions, in respect of those functions.

Bluebell Housing is a private company and is not a listed public authority. Whether a private provider delivering local-authority-commissioned accommodation is exercising “public functions” is fact-specific and unsettled, and we are not going to assert an answer to it on a website.

What is true, and is more useful to a commissioner than a borrowed claim: our commissioners do hold the duty, contracts commonly impose equivalent obligations on us directly, and we support them in meeting it — by giving them what they need for an equality impact assessment, by applying the same standards in the clauses above, and by telling them when something we are being asked to do would have an unequal effect.

The people who work here

The same Act covers employment. We recruit against what a job actually requires, we make adjustments for disabled applicants and staff, and we do not ask about health before offering a job except in the narrow circumstances the Act allows.

Our residents include people from every background we house, and our staff should too. That is not a slogan on a wall: a service whose staff have no experience of the lives its residents have led makes worse decisions. We are not going to publish a workforce figure to prove it, because no such figure has been supplied and an invented one would be worse than silence. See our modern slavery statement for the recruitment checks that protect people coming to work here.

Information we collect about equality

Information about your race, religion, health, disability, sex life or sexual orientation is special category data, and there are stricter rules about collecting it. We would only ask for it to check that we are treating people fairly, or to provide something you need.

Where we ask, answering is voluntary, saying nothing never counts against you, and it is kept separate from decisions about your home. What we hold and why is set out in our privacy policy.

TBD — whether we do this at all yet. Whether Bluebell collects equality monitoring data from applicants, residents and staff, what it collects, and what it does with it. Most of this data is special category data under Article 9 of the UK GDPR, so collecting it needs a lawful basis and an Article 9 condition before a single form asks for it. Until that is decided this page cannot say monitoring happens. It is a decision for Bluebell with its data protection adviser.

Getting information from us in a form you can use

Everything we send you can come in large print, easy read, braille, audio, or another language. We can arrange an interpreter, including British Sign Language. Tell us once and we record it.

This website is built to be usable with a screen reader, from a keyboard, and with your own text size and contrast settings — our accessibility statement says what has been tested and what is not right yet.

If you live in one of our homes, the residents page gathers the routes you may need in one place.

If you think we have discriminated against you

Tell us. Use our complaints policy. Say that you think it is discrimination, so that it is looked at as discrimination rather than as a service failure. You will not be treated differently for raising it — that would itself be unlawful.

You can also, at the same time or instead:

• Get free advice from the Equality Advisory and Support Service, from Citizens Advice, or from a law centre. None of them works for us.
• Bring a claim in the county court. Time limits for discrimination claims are short, so take advice early rather than waiting for our process to finish.
• Ask the council, or whoever commissioned your placement, to look at it under their own contract.

About this policy

TBD — the date this policy was adopted, who owns it, when it was last reviewed and when it is next due. It has to be reviewed when the scheme eligibility criteria are written, when the equality monitoring decision is made, and whenever a scheme is designated for a particular group.