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

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).

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.