Applying a gender impact assessment to a Financial Hardship Policy

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.

• Women are more likely to be represented among communities of people experiencing financial hardship and more likely to be earning below the minimum wage (Women’s Health Victoria 2022)
• Women are more likely to lead sole-parent households, have unpaid caring responsibilities for someone with a disability, and work part-time/earning less income (Women’s Health Victoria 2022)
• Women are more likely to be clients assisted by homelessness services and significantly more likely to be experiencing family violence (Women’s Health Victoria 2022)
• Where gender roles are entrenched, and women have not had access to money, if they have experienced abuse or are separated, they can be more likely to require financial hardship support from water authorities (Essential Services Commission 2015).

• Concepts of masculinity in regional Australia can restrict social connectedness and lead to social isolation and adverse mental health outcomes for men (Bonell et al. 2023)
• A culture of self-reliance in regional and rural areas can make men reluctant to seek help, even when in crisis (stakeholder consultation).

• Gender diverse people often face high levels of discrimination for not conforming to the traditional gender-binary model, often resulting in marginalisation, social and political isolation, and a higher prevalence of mental health issues (Larkin 2019)
• LGBTIQ+ people face greater social, health, wellbeing, and economic challenges than the general population (State of Victoria 2022), likely shaping their need to access financial hardship policies.

• CALD communities, particularly refugees and asylum seekers, face various issues that can exacerbate the experience of financial hardship and access to financial hardship support. These include limited knowledge of the process or concept of water supply and billing, difficulties in communicating in English, often alongside literacy problems in their first language, transience in accommodation, and low incomes (Wallis Consulting Group 2015).
• CALD communities, particularly communities that are newer, smaller, and disproportionately refugees, can also be particularly vulnerable to financial hardship and issues with water bill payment (Wallis Consulting Group 2015).
• Aboriginal and Torres Strait Islander people consistently earn lower average incomes from employment and private sources than non-Indigenous Australians and are more likely to be living on low incomes (Australian Institute of Health and Welfare 2021b).
• Older adults and pensioners, particularly those who are retired, no longer employed but still paying a mortgage, can experience bill stress. As of March 2021, women were more likely to be receiving the age pension than men (Australian Institute of Health and Welfare 2021a).
• Aboriginal and/or Torres Strait Islander communities experiencing fear of racism, disrespect, judgement, and a historical pattern of harmful government interventions may prevent Aboriginal people from accessing government support services (Nolan-Isles et al. 2021).
• People who are lesbian, gay, bisexual, transgender, intersex, or queer (LGBTIQ+) can face unique challenges and disparities in the quality of care when accessing services (Australian Institute of Family Studies 2021).
• Experiences of stigma or discrimination when accessing non-LGBTIQ+ specialist services can affect service engagement and potentially impact individuals’ health and wellbeing outcomes for segments of LGBTIQ+ communities (Perales 2016).

• Australian Institute of Family Studies (2021) ‘Inclusive communication with LGBTIQ+ clients’, accessed 24 May 2023.
• Australian Institute of Health and Welfare (2021a), “Age Pension Snapshot: 16 September 2021‘, accessed 24 May 2023.
• Australian Institute of Health and Welfare, 2021b, ‘Indigenous Income and Finance Snapshot: 16 September 2021’, accessed 24 May 2023.
• Bonell, S., Trail, K., Seidler, Z. et al. “There’s No Sewing Classes, There’s No Bedazzling Seminars”: The Impact of Masculinity on Social Connectedness and Mental Health for Men Living in Inner-Regional Australia’, Sex Roles 88, 52–67 (2023).
• Essential Services Commission, 2015, ‘Review of Hardship Measures taken by Metropolitan Water Businesses’, accessed 24 May 2023.
• Larkin B (2019) ‘Pride and prejudice: LGBTIQ community responses to disaster events worldwide’, Australian Journal of Emergency Management, 34(4):60-66.
• Nolan-Isles D, Macniven R, Hunter K, Gwynn J, Lincoln M, Moir R, Dimitropoulos Y, Taylor D, Agius T, Finlayson H, Martin R, Ward K, Tobin S and Gwynne K (2021), ‘Enablers and Barriers to Accessing Healthcare Services for Aboriginal People in New South Wales’, International Journal of Environmental Research and Public Health, 18(6):3014.
• Perales F (2019). ‘The health and wellbeing of Australian lesbian, gay and bisexual people: A systematic assessment using a longitudinal national sample’, Australian and New Zealand Journal of Public Health, 43(3), 281–287.
• State of Victoria, 2022, Pride in our Future: Victoria’s LGBTIQ+ Strategy 2022-32., accessed 24 May 2023.
• Wallis Consulting Group (2015) ‘Water Billing Hardship Arrangements: a report of interviews with financial counsellors, water customers and advocate organisations', accessed 24 May 2023
• Women’s Health Victoria (2022) Victorian Women’s Health Atlas, Gender Equality Fact sheets accessed 21 May 2023.

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.