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Applying a gender impact assessment to a Financial Hardship Policy

Name of initiative: Financial Hardship Policy

Policy/program/service: Policy

New or up for review: Up for review

Sector: Essential services (water authorities)

This case study has been drawn from real examples, however the narrative is fictional.


Xian is the Customer Service Manager at a regional water authority in Victoria. She and her team are responsible for implementing her organisation’s Financial Hardship Policy.

This policy is the overarching document that guides how the organisation supports customers experiencing financial difficulties. It aims to ensure all customers will continue to have access to essential water services, regardless of their capacity to pay.

This year the Financial Hardship Policy is up for review. Because the policy has a direct and significant impact on local communities, Xian and her team must complete a gender impact assessment (GIA) as part of their policy review.

While Xian will lead the GIA process, she will need to work with Finance, Customer Support, and People and Capability team representatives to complete the 4 key GIA steps.

The group plan to approach the GIA as follows:

  • use the 4 steps in the Commission's GIA toolkit and templates as a guide
  • begin the GIA process with a 90-minute workshop to brainstorm critical issues related to gender and financial hardship (Step 1)
  • dedicate time for independent research and consultation to document different ways that women, men and gender diverse customers experience financial hardship and access this policy (Step 2)
  • document options for policy change and discuss gendered risks and benefits of each option in a workshop with all group members (Step 3)
  • document final recommendations for policy change and submit them for approval by the People and Capability team (Step 4)
  • file GIA documentation in the organisation’s Content Management system to support legislated GIA progress reports every two years.

Step 1: Define the issues and challenge assumptions

Xian knows the group has different levels of awareness and understanding of the requirement to complete GIAs. Some team members also have a limited experience with terms like intersectional gender equality, so Xian plans to use some time to address these gaps and share knowledge.

Xian begins the session with a brief overview of GIA requirements under legislation. She shares some critical statistics about gender inequality in the local community to illustrate what it might mean to apply a gender lens to issues of financial hardship. She also works with the group to make sure they understand what is meant by ‘intersectionality’ and why it is essential in GIAs.

The group then discusses their responses to the questions in GIA Template 1.

Defining the issues

The group agrees that the Financial Hardship Policy should provide a clear and consistent guide for delivering support to customers experiencing short-term or long-term financial difficulties.

The Essential Services Commission, as the independent regulator for Victorian water authorities, requires all authorities to have hardship policies in place. These policies should ensure all customers have access to essential water services, irrespective of their capacity to pay. They should also assist customers experiencing financial hardship to pay off outstanding debts.

The group agrees the policy also defines the mechanisms for hardship support (i.e., what support options are available) and how support is provided (i.e., treating all customers with dignity and respect). They agree this support is available for all community members, regardless of gender.

Challenging assumptions

  • The group agrees the policy includes an explicit commitment to treat all customers with respect and sensitivity and without judgement, and the best way to achieve this is with stakeholder consultation. Customer Service team members also note that they take a genuine partnership approach when supporting a customer to negotiate payment plans or request additional support.

    Although the group has yet to consult directly with customers in the design of this policy, they note that they regularly check in with external providers, including financial counsellors, to inform and improve the delivery of services.

  • The team agrees that community members might 'access' this program differently. For example, they might request support during a routine phone call or be referred to the customer support team by a financial counsellor, family violence or housing support provider.

    Currently, the team does not keep gender data on customer inquiries. They have yet to complete any gender-disaggregated analysis to understand whether customers of different genders are over-represented or under-represented among those accessing hardship policies. Without specific data, the group agrees that women may be more likely to access the Financial Hardship Policy, due to experiencing higher rates of family violence, insecure employment, and lower income due to unpaid caring responsibilities at home and in families.

    Some group members start to feel overwhelmed with the level of information they might need to start collecting. Xian reminds the group that the legislation intends to drive incremental change. She suggests there might be just two or three key things the organisation can resource now to promote improved access for people of all genders. The organisation can’t do everything at once, but the legislation means they have to get started.

  • The group agrees that everyone accessing the Financial Hardship Policy wants to ensure they can maintain access to essential services.

    There are a range of factors that lead to customers accessing the policy, including:

    • unemployment,
    • issues with physical or mental health,
    • limited English proficiency and awareness of Australian billing systems,
    • relationship breakdowns,
    • unstable employment,
    • insecure housing,
    • family separations and
    • experiences of family violence.

    The group agrees that customer outcomes are much better if customers access the policy and related supports as early as possible in the hardship cycle. They note that some customers might speak up immediately, but not everyone will feel comfortable doing so. Sometimes, if a customer service team member is appropriately trained, they will also feel confident to proactively offer services and help customers at risk of financial hardship to access support.

    In many cases, customers will only speak up once in crisis or when referred by financial counsellors and other service providers. They may feel shame or fear. They may be too overwhelmed to access support because they need help understanding the systems. Or they may not feel safe to disclose their experiences.

    The group agrees it would be helpful to complete independent research documenting the different experiences of women, men and gender diverse customers so they can think about how this applies to their understanding of policy implementation. They must also consider how other factors such as Aboriginality, age, cultural identity, disability, or sexual orientation might intersect with gendered experiences.

  • The group agrees that women who are single parents, women with younger dependents or dependents with additional needs, or women who are experiencing family violence and caring for children may be more frequently referred to the customer service team by external services. They think that men in their regional community might experience higher rates of issues with mental health, which could affect their ability to maintain secure employment and regular income to cover bills for essential services.

    Some group members wonder how much can really be done to change the policy to meet so many different customers' needs, particularly within the legislative framework. Xian reminds the group that this is just the exploratory discussion stage. Once group members complete more independent research, they will need to document some clear options for policy change.

  • One customer service team member acknowledges that how he first responds to a customer's disclosure of hardship experiences can influence whether or not that customer accesses support in the future. He notes that he and his colleagues would like to understand how to identify hardship needs or recognise signs of family violence, so that he can offer services more proactively. He'd also like to know more about the experience of family violence among LGBTIQ+ community members. Another team member wonders about potential barriers for older adults, people from CALD backgrounds, and people with disabilities.

    Xian reminds the group that the process of the GIA will respond to many of these questions, and the independent research that group members will now complete will be an excellent opportunity to learn more about these experiences and how the team can better support people needing to access the hardship policy.

Broadening the issues with a gendered lens

After completing Step 1, the team has a list of questions to investigate further. They will answer some questions through desktop research and others through consultation with key stakeholders. Questions include:

  • What do we know about the state and nature of intersectional gender inequality in our customer communities?
  • How might this inequality privilege, disadvantage or exclude women, men and gender diverse customers who need to access hardship policy services?
  • How might support needs differ for women, men, and gender diverse customers who are Aboriginal and Torres Strait Islander, have different cultural identities and English language proficiency levels, ages, disabilities, and sexual orientations?
  • What do we know about the gender split of hardship policy users and their experience accessing the services provided under this policy? Can we analyse their experiences and access by gender and other intersectional attributes?

Step 2: Understand the policy context

  • Xian and her team follow the process in GIA Template 2 to address some of the knowledge gaps they have identified
  • They explore internal data, complete desktop research, and consult with stakeholders to develop a clearer picture of how the Financial Hardship Policy might inadvertently exclude diverse customer communities
  • They aim to complete this work over a few weeks so that they can use it to inform the development of policy improvement options in GIA Step 3.

Investigating internal data

Xian and her team have limited internal data on the gender of customers accessing hardship supports outlined in the policy. This limits their ability to evaluate customer access and experience by gender.

Without this data, Xian takes time to review other internal information already collected by the organisation. This includes:

  • organisational strategies and action plans, including data from customer consultations that informed these plans
  • consultation data from water pricing consultation processes
  • enquiries and complaints handling data
  • general (non-disaggregated) data on customers accessing financial hardship supports.

Data, statistics and desktop research

Team members also complete independent research using a range of external sources. They refer to the Commission’s compilation of data sources for conducting a gender impact assessment when they begin this external research.

Xian and her team review data from some of the following sources:

  • Australian Bureau of Statistics (ABS)
  • HILDA Survey Data
  • Victorian Women’s Health Atlas
  • Australian and Torres Strait Islander Data Archive (ATSIDA).

They also review data and reports from peak bodies supporting diverse communities, regulatory bodies guiding hardship support, and peak bodies providing financial counselling and support services. Publications they review come from organisations, including:

  • Essential Services Commission
  • The National Debt Helpline
  • Homelessness Australia
  • Australian Institute of Health and Welfare
  • National LGBTI Health Alliance
  • Rainbow Health Australia
  • Victorian Aboriginal Childcare Agency
  • Victorian Aboriginal Community Controlled Healthcare organisation.

Stakeholder consultation

Xian would like to use stakeholder consultation to better understand the lived experiences of local community members who have accessed financial hardship support. She understands that these 'voices' need to be clear in defining how the policy can best respond to them.

Xian speaks with representatives from some of the following groups:

  • Financial counsellors
  • Local family violence service providers
  • CALD service providers
  • Groups focusing on men’s mental health
  • Disability services
  • Housing services
  • Local Aboriginal and Torres Strait Islander community groups and elders.

Evidence collected by Xian and her team

Step 3: Evaluate the options

  • Based on the evidence gathered, Xian uses GIA Template 3 to document two possible options for policy review.
  • She brings the team back together for a 60-min session to discuss these options and consider any gendered risks and benefits.
  • The team also discusses practical resourcing and capacity limitations for their preferred option.

Xian notes that the current Financial Hardship Policy aligns with guidance provided by the industry regulator, the Essential Services Commission. However, she believes they could make a series of amendments to improve the policy and ensure it also meets the requirements under the Gender Equality Act.

She asks the team to consider the gendered benefits and risks of continuing to implement the policy as is (Option 1) or making amendments to improve access and benefits for diverse people of all genders (Option 2).

  • Xian and her team discuss the following concerning this option:

    Gendered benefits of continuing with existing programming

    • the existing policy is open to all customers (though the group agrees it does not take targeted steps to ensure people of all genders can access and engage with various hardship support options).

    Gendered risks of continuing with existing programming

    • the existing policy and program are not adequately designed to address the specific needs and experiences of diverse people of different genders
    • intersectional gender equality is not an established priority to guide policy implementation
    • the policy does not prescribe sufficient training for customer service staff to implement hardship policy and deliver support that promotes gender equality and ensures gender equitable access
    • lack of understanding of the hardship experiences of many customers, in particular women experiencing family violence, can lead to unsafe outcomes for customers
    • without targeted changes, the policy may continue to perpetuate intersectional gender inequality, reinforcing unbalanced norms, roles, and relations.

    Overall impact of continuing with existing programming

    The team agrees that continuing with Option 1 would see a negative gender impact.

  • Xian notes there are several changes the team could make to the policy to ensure it responds to regulatory requirements set by the Essential Services Commission and GIA regulations under the Gender Equality Act. She believes both regulatory bodies are working to achieve the same aim – inclusive service delivery that treats all customers with dignity, sensitivity and respect.

    Xian presents several actions the team could take to ensure the Financial Hardship Policy better supports Victorians of all genders and promotes gender equality:

    • Amend policy wording to integrate a commitment to promoting gender equity in service delivery, alongside respect and sensitivity.
    • Integrate commitments to training of customer service staff, in particular on intersectional gender equity in service provision and responding to family violence.
    • Integrate a list of centres for referral for family violence and homelessness support services.
    • Improve policy promotion by ensuring commitments to gender equity are prominently displayed on the organisation's website homepage and specific pages relating to the Financial Hardship Policy.
    • Target providers and referral organisations (e.g., family violence service providers) with information outlining hardship provisions.
    • Engage family violence providers and homelessness support services in regular feedback on hardship policy provisions and customer service delivery.

    Xian and her team discuss the following concerning this option:

    Gendered risks of the program

    • potential backlash from the community who believe the organisation is favouring women who experience family violence or demonising men as perpetrators (though the group agrees the benefits of this program outweigh this risk).

    Gendered benefits of this option

    • Will reduce barriers to women and gender diverse people experiencing family violence and may encourage people in such circumstances to explain this when seeking support.
    • Customer service staff will have more confidence to support customers they believe might be experiencing financial hardship as a result of family violence.
    • Customer service staff will deliver services in a trauma-informed, gender equitable way.
    • Stronger partnerships with experienced service providers supporting different communities of men, women and gender diverse people experiencing vulnerabilities in the community.

    Overall impact of this option

    The team agrees that Option 2 would deliver an overall positive gender impact.

Step 4: Finalise recommendations

  • Xian documents specific recommendations in GIA Template 4.
  • She shares her completed GIA template with the group for final review and feedback.
  • Xian submits the documented GIA recommendations to the People and Capability team for approval and files GIA documentation.

Xian formally recommends that the organisation proceed with Option 2. She documents her specific recommendations as follows:

  • Update the Financial Hardship Policy to include the following:
    • gender equitable service delivery as a priority
    • commitment to regular training for customer service staff
    • commitment to data collection and gender-disaggregated review of customer feedback and complaints handling
    • list of referral services and key contacts.
  • Schedule and deliver capacity-building training for the customer service team, including:
    • annual Family Violence Training (incl. responding to disclosures of family violence) for all frontline customer service staff
    • biannual Gender Equity Essentials training for customer service staff, including training on the intersection of gender in/equality and sexism, racism, ableism, homophobia, transphobia, and biphobia.
  • Update the corporate website to include a prominent display of Financial Hardship Policy and related supports
  • Review existing data collection processes to consider the feasibility of gender-disaggregated data on customer feedback and complaints.

Preparing for progress reporting to the Commission

  • Xian files the completed GIA template in her organisation’s content management system.
  • This GIA template will inform progress reports for the Commission for Gender Equality in the Public Sector.
  • To prepare for progress reporting, Xian will also need to upload a short summary of actions taken as a result of this GIA.

Xian's organisation must submit progress reports every two years to the Commission for Gender Equality in the Public Sector. These reports must include the following:

  • detail of the policies, programs and services that were subject to a GIA
  • actions taken as a result of the GIA.

All of Xian’s recommendations were approved, and the team is proud of their work to promote gender equality. Xian files her approved GIA template in her organisation's content management system, for use in progress reporting. Other teams may also access this template to use as a reference when completing their GIAs.

These files will be used as a reference by the GIA Lead in People and Capability when they complete and submit their organisation's progress report to the Commission for Gender Equality in the Public Sector. Under the Gender Equality Act, these reports are due every two years.

Summary of actions taken:

  • a revision of the Financial Hardship Policy will include gender equity as a priority
  • the customer service team will complete training on responding to disclosures of family violence with an intersectional gender lens
  • the Financial Hardship Policy will include an appendix listing referral services
  • a customer flowchart will be developed to support customers in accessing both family violence and financial hardship support services
  • the website will be updated to reflect these changes in promoting gender equality.

Reviewed 22 June 2023