S75 Equality And Good Relations Screening Form
This is a revised service/function.
Operational Area: Environmental Services
Title: Pilot the introduction and use of an electronic barrier system using Automatic Number Plate Recognition (ANPR) in 1 Council Carpark
Brief Summary
Council currently uses overhead height‑restriction barriers in several seaside car parks to prevent illegal camping. These barriers restrict vehicles above a set height. Residents and visitors who require access with larger vehicles; including accessibility‑adapted vehicles, community transport, buses, and emergency services; can request a code to open the barrier, but they must manually pull it across and close it again.
Feedback from current users demonstrates that some users particularly disabled people, older people, and those with mobility impairments find the existing barrier difficult to reach, operate, and close, compounded by adverse weather conditions.
As a result, Council intends to undertake a six‑month pilot to introduce an electronic barrier system using Automatic Number Plate Recognition (ANPR) technology in one Council‑managed car park.
What is it trying to achieve? (intended aims and outcomes)
The pilot will test whether an ANPR‑operated barrier improves accessibility and ease of access compared with the current manual system. The system will automatically recognise authorised vehicle registrations and raise the barrier without drivers needing to exit their vehicle or operate any controls.
The pilot will allow Council to:
- assess whether the ANPR system improves accessibility and user experience.
- identify operational or technical issues.
- gather feedback from users and stakeholders.
- provide decision-making evidence if the pilot should be adopted permanently, amended, or discontinued.
- support access to an accessible beach and changing facilities.
- Assist in the verification and investigation of incidents involving alleged vehicle damage by providing an auditable access record.
Who owns and who implements each element of the function, service, policy, procedure, project, strategy, plan or guidance?
Infrastructure team own and implement all elements of car parking.
Other policies etc. which have a bearing on this function, service, policy, procedure, project, strategy, plan or guidance?
Strategies:
- CC&GBC car parking strategy 2017 – 2027.
- Councils Equality Scheme.
- Equality Action Plan.
- Councils Corporate Strategy.
- Councils Community Plan.
- Councils Good Relation Strategy.
- Destination Management Strategy.
Legislation:
- Northern Ireland Act 1998 (Section 75).
- Local Government Reform Act 2014.
Available Evidence
Evidence to help inform the screening process may take many forms. Public authorities should ensure that their screening decision is informed by relevant data.
What evidence/information (both qualitative and quantitative have you gathered to inform this function, service, policy, procedure, project, strategy, plan, or guidance? Specify details for relevant Section 75 categories.
It is proposed that all Section 75 categories will be considered via:
- Quantitative evidence has been sourced via the NI Census in 2021 and the Northern Ireland Life and Times Survey 2024.
- The screening also considered the work of the Inclusive Mobility and Transport Advisory Committee (IMTAC), which highlights the importance of inclusive design to remove barriers experienced by disabled people and older people when accessing services and transport infrastructure.[1]
- Feedback from users of the current system detailed by complaints and requests for access and reasonable adjustments.
- ICO (Information Commissioner’s Office) – ANPR Guidance for lawful, fair, and transparent use of ANPR, including the need for a DPIA, minimising cameras, justifying locations, clear signage, and strong governance controls.[2]
- British Parking Association (BPA), highlights the operational benefits of ANPR for councils, reduced costs, and improved compliance.[1]
[1] https://www.britishparking.co.uk/ANPR
[1] https://view.officeapps.live.com/op/view.aspx?src=https%3A%2F%2Fwww.imtac.org.uk%2Ffiles%2Fimtac%2F2025-10%2FImtac%2520Annual%2520Report%25202025%2520%2528Final%2520Version%2529%2520Word_0.docx&wdOrigin=BROWSELINK
[2] https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/cctv-and-video-surveillance/guidance-on-video-surveillance-including-cctv/additional-considerations-for-technologies-other-than-cctv/automatic-number-plate-recognition-anpr/
Section 75 Category and Details of Evidence/Information
- The Census statistics in 2021 collated by NISRA statistics detailed the usual resident population of Causeway Coast & Glens Local Government District to be 141,746 accounting for 7.45% of the N.I. total. [1] Statistical information with regards to the Districts makeup and individuals therein was also reviewed.
- UK councils such as Cornwall already use ANPR effectively within existing legislation, supporting the view that it is an established and accepted practice in local‑authority parking management, although we would be the first council to introduce it in Northern Ireland on the basis of disabled accessibility.[2] [3]
- The British Parking Association highlighted issues with double charging, however this is outside the remit of this pilot, which only permits access, carparking charges will remain using the current systems.
- Previous discussions with local disability groups and disabled drivers highlighted the need for accessibility for high rise wheelchair accessible vehicles to be of greater importance than the cost of parking, i.e., accessibility, not affordability.
- The screening has considered:
- feedback regarding accessibility difficulties with the current barrier system.
- potential barriers faced by disabled people and older people when using manual or difficult-to-reach controls.
- equality obligations under Section 75 of the Northern Ireland Act 1998.
- the Disability Discrimination Act 1995.
- The pilot itself will also provide additional evidence and user feedback to inform future decision-making.
- Consideration given to the led lighting strips that may be used with regard to light pollution and certain conditions such as epilepsy.
- Consideration has also been given to the fact that the pilot car park is in a tourist area adjacent to an award-winning beach which may attract individuals whose main language may not be English and who may experience additional barriers if instructions are complex.
- The proposed ANPR barrier system is intended to reduce physical access barriers associated with the current barrier arrangement. This aligns with wider accessibility principles identified by IMTAC regarding the importance of reducing barriers that can limit independent access for disabled and older people.
- The pilot provides an opportunity to apply inclusive design principles in practice by testing whether technology can remove or reduce barriers experienced by disabled and older users. Feedback gathered during the pilot will help ensure that future decisions are informed by lived experience and accessibility considerations.
- No log currently in operation to monitor access requests, figures are unknown, but this pilot scheme will support improved data collection.
ANPR is unlikely to create rural‑specific issues, but council has considered connectivity, non‑standard vehicles, seasonal visitor patterns, and public sensitivity around surveillance technologies, alongside potential seasonal impacts due to the coastal location.
[1] Source: Northern Ireland Statistics website: www.nisra.gov.uk census-2021-ms-a01.xlsx (live.com)
Crown copyright material is reproduced with the permission of the Controller of HMSO.
Religious Beliefs
According to the 2021 Census, residents of Causeway Coast and Glens Borough Council broadly reflect the religious profile of Northern Ireland, with 40.1% Roman Catholic (45.7% regionally) and 51.2% Protestant and Other Christian (43.5% regionally). A further 0.8% in the borough (1.5% regionally) identified with other religions, while 7.9% locally (9.3% regionally) reported no religion or chose not to state one.
As of 16 December 2025, Council employed 744 staff, comprising 37.5% Roman Catholic, 55.8% Protestant, and 5.7% Non-Determined, reflecting representation from across the main community backgrounds.
There are no specific religious objections to ANPR or surveillance technologies, although some faith communities may express general concerns about privacy, dignity, and the ethical use of personal data. Such concerns should be alleviated by clear communication, transparent data‑handling practices, and compliance with ICO guidance.
The pilot will help identify any currently unknown or unforeseen impacts.
Political Opinion
The 2024 Northern Ireland Life and Times Survey shows that the Alliance Party (24%) is the party people feel closest to, followed by Sinn Féin (20%), with unionist parties at 22% and nationalist parties at 30%; 17% chose none or didn’t know, highlighting both Alliance’s growth and a notable proportion of the population remaining disengaged from or undecided about party politics. (this information is not available at local government level).
No staff information is held regarding this category.
There are no specific political objections to ANPR use in Northern Ireland, but due to historical sensitivities around surveillance transparency, proportionality and clear communication are particularly important.
The pilot will help identify any currently unknown or unforeseen impacts.
Racial Group
According to the 2021 Census, while the local population is becoming more diverse, 97.8% still speak English as their main language, with Polish, Irish, Portuguese, Arabic, Bulgarian, Chinese, and Cantonese also spoken locally.
As of 1 December 2025, 93.4% of Council staff identified as White/White European, 0.7% as Other, and 5.9% were Unknown.
There are no specific race‑related impacts associated with ANPR use, although some minority ethnic communities may have general concerns about fairness, trust, and data use, which can be mitigated through clear and accessible communication.
A mix of clear signage using visual icons, information on the website to support multilingual users, and engagement with local community and faith groups will ensure people from a wide range of backgrounds are informed about the ANPR system.
The pilot will help identify any currently unknown or unforeseen impacts.
Age
According to the 2021 Census, the Causeway Coast and Glens Borough have a population of 141,745, with a slightly higher proportion of residents aged 50 and over, indicating an ageing population.
NISRA’s 2020-based projections show this trend continuing, with people aged 65+ expected to outnumber children by 2027.
As of 6 June 2024, the Council employed 744 staff, with the majority (79%) aged 40 and over.
Age and ability to pull the current manual barriers has been cited as an obstacle.
Older people may be more likely to experience lower digital confidence, so the current application system of contacting Council via telephone will be maintained. Older people may also have trouble reading signage if it is small, complex, or text‑heavy, so this will be mitigated with clear, simple signage, staff support during rollout and offline options for application.
Younger people may have higher digital literacy and greater familiarity with automated systems however still have concerns about data use, especially around surveillance and privacy, this will be mitigated with clear Data Protection and data storage information.
Council can reach out to school transport and youth‑service organisations to ensure their vehicles are correctly registered if needed.
ANPR records vehicle registration numbers only, not age or personal data.
There are no specific age‑related impacts associated with ANPR use, although older people may need clearer information and support, and younger people may have general concerns about data use and privacy. According to the 2021 census, the data shows a clear relationship between age and disability. Across Northern Ireland, the proportion of people reporting a long-term health problem or disability that limits their day-to-day activities increases significantly in older age groups. At the same time, the population aged 65 and over increased by almost 25% between 2011 and 2021, demonstrating the growing importance of accessible services, facilities, and parking for an ageing population[1]
The pilot will help identify any currently unknown or unforeseen impacts.
Marital Status
According to Census 2021, Causeway Coast and Glens reflects Northern Ireland trends, with the highest proportion of residents married (47.8%), slightly above the NI average of 45.6%. All other marital status categories are broadly in line with regional figures, except for civil partnerships (0.14%), which are slightly lower than the NI average of 0.18%. Same-sex marriage has been legal in Northern Ireland since 13 January 2020.
As of 16 December 2025, Council staff (n=744) are 55% married, 27% single, and the remainder divided across divorced, separated, widowed, civil partnership, or other, with 7% unknown.
As the proposed system will rely on a registered number plate married couples, cohabiting partners, or families will continue to be able to share vehicles.
There are no specific marital‑status impacts associated with the proposed pilot as the system does not collect personal data of this kind, though clear communication will support all household types understand how it operates.
The pilot will help identify any currently unknown or unforeseen impacts.
Sexual Orientation
The 2021 Census included a question on sexual orientation for the first time. In Causeway Coast and Glens, 91.3% of residents aged 16+ identified as straight or heterosexual, 1.4% as gay, lesbian, bisexual, or another orientation, and 7.3% preferred not to say or did not state. Patterns were broadly similar to Northern Ireland overall, with younger age groups more likely to identify as LGBT+, reflecting generational differences.
The Council currently has no workforce data on this Section 75 category. No equality issues have been identified, and inclusive communication within the campaign will support all Section 75 groups to have equal access to the information.
There is no specific sexual orientation impacts associated with the proposed pilot as the system does not collect personal data of this kind, though clear communication will support everyone to understand how it operates.
The pilot will help identify any currently unknown or unforeseen impacts.
Men and Women Generally
According to Census 2021, the population of Causeway Coast and Glens Borough is evenly split by gender, with 49.3% male and 50.7% female, similar to Northern Ireland overall. As of 16 December 2025, Council staff (n=744) are 59.7% male and 40.3% female.
No equality issues have been identified, and inclusive communication within the pilot will support all Section 75 groups to have equal access to the information.
Women are statistically more likely to be primary carers so the pilot may remove the current access barriers identified.
The proposed pilot as the system does not collect personal data of this kind, though clear communication will support everyone to understand how it operates.
The pilot will help identify any currently unknown or unforeseen impacts.
Dependants
In Causeway Coast and Glens, 28% of households include dependent children, slightly below the NI average of 29.2%, and 9.6% are lone-parent households, compared with 10.6% regionally. The borough has fewer single-person households under sixty-six but a higher proportion of older households, reflecting an ageing population. Around 12.3% of residents provide unpaid care, broadly in line with Northern Ireland overall, with those aged 40–64 most likely to be carers.
As of 6 June 2024, Council staff (n=744) include 33% with children, 2% adults only, 35% with no dependents, and 30% unknown.
As the proposed system will rely on a registered numberplate carers will continue to be able to share vehicles. Parents/carers with dependants with mobility needs will benefit from more accessible access.
The pilot will help identify any currently unknown or unforeseen impacts.
Disability
According to Census 2021, 36% of residents in Causeway Coast and Glens have a long-term health condition or illness that limits daily activities, slightly above the NI average of 34.7%. Common conditions include long-term pain, mobility or dexterity limitations, breathing difficulties, and mental health issues.
As of 16 December 2025, Council staff (n=744) include 22 employees (3%) with a disability and 722 (97%) without.
This is the most significantly affected group.
People with:
mobility impairments.
wheelchair users.
people with visual impairments.
people using mobility scooters with adapted vehicles, all need to be able to access carparks without barriers.
The pilot specifically seeks to reduce these barriers; it will help identify any currently unknown or unforeseen impacts and provide evidence to determine if this system is a suitable mitigator.
7.8% of the N.I. population as of the 7th of April 2025 according to the Department of Infrastructure have possession of a disability badge.
1.51% of the Causeway Coast and Glens Borough Council area requires the use of a Wheelchair.[1]
This highlights the need for automatic accessible height barrier.
Screening Question 1
What is the likely impact on equality of opportunity for those affected by this function, service, policy, procedure, project, strategy, plan or guidance?
Section 75 Category - Positive impact (it could benefit), Neutral or Negative impact (it could disadvantage).
Gender
Women, Men, Transgender men/women, Other: Positive impact.
The pilot may have a positive impact for any gender who currently experiences difficulty reaching the barrier and moving it.
This may improve safety, and ease of access.
Race
The categories used in the Race section are those used in the 2011 census. Consideration should be given to the needs of specific communities within the broad categories.
Asian, Black, Chinese, Mixed race White, Other please specify:: Neutral Impact.
No race specific impact identified.
Disability
Long term health impairment could include mental health problems, asthma, heart conditions, chronic fatigue etc.
Positive Impact.
The pilot is expected to have a positive impact for disabled people, particularly individuals with:
- reduced mobility.
- chronic pain conditions.
- dexterity impairments.
- upper limb impairments.
- conditions affecting movement or coordination.
The ANPR system may remove or reduce the need to:
- stretch or reach from a vehicle.
- exit a vehicle to access controls.
- manoeuvre into awkward positions to activate the barrier.
This may improve independence, dignity, safety, and ease of access.
Sexual orientation
Heterosexual, lesbian, gay men, bisexual, others: Neutral Impact.
No sexual orientation specific impact identified.
Age
Older People: Positive Impact.
Younger people and children: Neutral Impact.
Older people may benefit from reduced physical effort and improved ease of access when entering or exiting the site.
Political Opinion
Neutral Impact.
No political opinion specific impact identified.
Religious Belief
Neutral Impact.
No religious belief specific impact identified.
Marital Status
Neutral Impact.
No marital status specific impact identified.
Dependants
Positive Impact.
The pilot may have a positive impact for carers as they would no longer have to exit the vehicle or manoeuvre the barrier.
This may improve safety, and ease of access.
Screening Question 2
Are there opportunities to better promote equality of opportunity for people within any of the Section 75 categories?
Section 75 Category If Yes, provide details If No, provide details.
Gender (Women, Men, Transgender men/women, Other please specify).
Yes.
The pilot presents opportunities to:
- reduce physical barriers to access.
- support independent access.
- gather evidence to support more inclusive service delivery.
The proposal aligns with the aim of removing unnecessary barriers for service users.
Race The categories used in the Race section are those used in the 2011 census. Consideration should be given to the needs of specific communities within the broad categories.
(Asian, Black, Chinese, Mixed race, White, Other please specify).
No significant direct change, however, there may be an indirect positive impact through clearer communication.
Disability Long term health impairment could include mental health problems, asthma, heart conditions, chronic fatigue etc.
Yes.
The pilot presents opportunities to:
- improve accessibility for disabled people and older users.
- reduce physical barriers to access.
- support independent access.
- gather evidence to support more inclusive service delivery.
The proposal aligns with the aim of removing unnecessary barriers for service users.
Sexual orientation Heterosexual, lesbian, gay men, bisexual, others.
No significant direct change.
Age Older People, Younger people and children.
Yes.
The pilot presents opportunities to:
- improve accessibility for older users.
- reduce physical barriers to access.
- support independent access.
- gather evidence to support more inclusive service delivery.
The proposal aligns with the aim of removing unnecessary barriers for service users.
Political Opinion
No significant direct change.
Religious Belief
No significant direct change.
Marital Status
No significant direct change.
Dependants
Yes.
The pilot presents opportunities to:
- improve accessibility for people with dependants.
- reduce physical barriers to access.
- gather evidence to support more inclusive service delivery.
The proposal aligns with the aim of removing unnecessary barriers for service users.
Screening Question 3
To what extent is the policy likely to impact on good relations between people of different religious belief, political opinion or racial group?
Section 75 Category Details of policy impact Level of impact major/minor/none.
Religious Belief / Political Opinion / Racial Group
No adverse impact on good relations has been identified.
The proposal is operational in nature and applies equally to authorised users regardless of background.
Screening Question 4
Are there opportunities to better promote good relations between people of different religious belief, political opinion or racial group?
Section 75 Category If Yes, provide details If No, provide details.
Religious Belief / Political Opinion / Racial Group
No. The proposal has no remit to impact on good relations.
Additional Considerations
Generally speaking people can fall into more than one Section 75 category. Taking this into consideration, are there any potential impacts of the function, service, policy, procedure, project, strategy, plan or guidance on people with multiple identities? (For example: disabled minority ethnic people, disabled women, young Protestant men, young lesbians, gay and bisexual people.)
Older people with disabilities
- May benefit most from automated, predictable access that removes the need for physical interaction (e.g., fixed barriers and/or reaching for buttons).
Minority ethnic women with caring responsibilities who are also new migrants.
- May have lower trust in public authorities due to experiences in other countries.
- Language barriers may make signage or instructions harder to understand.
Lone parents with caring responsibilities and disabilities
- Rely heavily on predictable access for school runs, appointments, or caring duties.
LGBTQ+ people who are also younger or from minority ethnic backgrounds.
- May have heightened concerns about privacy or data use.
- The system does not collect or infer sexual orientation, which reduces risk.
Disabled minority ethnic people
- May face additional barriers if English is not their first language and signage is text‑heavy.
- Disabled people benefit from automated access that removes the need to reach for tickets or interact physically with equipment.
- The proposed ANPR pilot has the potential to positively impact individuals with multiple identities by reducing the need for physical interaction with the barrier and improving independent access.
There is no evidence of negative impacts on people with multiple identities.
In fact, automated barriers can enhance fairness, consistency, and accessibility, particularly for:
- disabled people
- older people
- carers
- minority ethnic communities
- people with lower digital confidence
Potential issues identified relate to communication and accessibility, which can be mitigated through clear signage, multilingual materials, and support during the pilot.
Provide details of data on the impact of the function, service, policy, procedure, project, strategy, plan or guidance on people with multiple identities. Specify the relevant Section 75 categories concerned.
Census 2021/NISRA data highlighted:
15,951 people (11.25%) reported mobility or dexterity limitations affecting physical activities.
17,396 people (12.27%) reported long-term pain or discomfort.
8,914 people (6.29%) reported deafness or partial hearing loss.
These figures directly support the rationale for introducing an ANPR barrier pilot aimed at reducing physical access difficulties.
Rural users, older people, and disabled people may rely more heavily on private vehicle access and may be disproportionately affected by difficult physical barriers.
Disability Considerations
Is there an opportunity to better promote positive attitudes towards disabled people by altering this function, service, policy, procedure, project, strategy, plan or guidance?
Yes.
If yes, please give further information and examples:
The pilot provides an opportunity to apply inclusive design principles in practice by testing whether technology can remove or reduce barriers experienced by disabled and older users. Feedback gathered during the pilot will help ensure that future decisions are informed by lived experience and accessibility considerations.
Is there an opportunity to encourage participation by disabled people in public life by altering this function, service, policy, procedure, project, strategy, plan or guidance?
Yes.
Please give further information and examples:
By seeking feedback from disabled people with the end aim to remove barriers and support independent inclusion.
Screening Decision
Likely Impact: Minor
If the decision is to subject the policy to an equality impact assessment (i.e. likely impact – Major), please provide details of the reasons for this:
N/A.
If the decision is not to conduct an equality impact assessment (i.e. likely impact = Minor) the Council should consider if the policy should be mitigated or an alternative policy be introduced:
No significant adverse impacts have been identified at this stage.
Potential risks identified include:
- registration recognition failures.
- access issues for visitors or temporary users.
- technological faults.
- privacy concerns relating to ANPR data collection.
Mitigations during the pilot will include:
- alternative access arrangements where required.
- monitoring of system performance.
- clear signage and user guidance.
- compliance with data protection requirements.
- opportunities for users to provide feedback.
If the decision is not to conduct an equality impact assessment (i.e. likely impact = None), please provide details of the reasons for this:
N/A.
Mitigation
When the Council concludes that the likely impact is ‘Minor’ and an equality impact assessment is not to be conducted, the Council may consider mitigation to lessen the severity of any equality impact, or the introduction of an alternative policy to better promote equality of opportunity or good relations.
Can the policy/decision be amended or changed or an alternative policy introduced to better promote equality of opportunity and/or good relations?
Yes.
If YES, give the reasons to support your decision, together with the proposed changes/amendments or alternative policy:
Mitigations during the pilot will include:
- alternative access arrangements where required.
- monitoring of system performance.
- clear signage and user guidance.
- compliance with data protection requirements.
- opportunities for users to provide feedback.
Timetabling And Prioritising
If the policy/decision has been ‘screened in’ for equality impact assessment, then please answer the following questions to determine its priority for timetabling the equality impact assessment.
On a scale of 1 to 3, with 1 being the lowest priority and 3 the highest, assess the policy in terms of its priority for equality impact assessment.
Priority Criterion
Rating (1 to 3)
Effect on equality of opportunity and good relations: N/A.
Social Need: N/A.
Effect on people’s daily lives: N/A.
Relevance to the Council’s functions: N/A.
Monitoring
Please outline proposals for future monitoring of the policy/decision:
During the six-month pilot period, the organisation will:
- monitor operational effectiveness.
- gather user feedback.
- review accessibility outcomes.
- identify any unintended impacts, complaints, or issues.
- assess whether additional reasonable adjustments are required.
A review report will be completed at the end of the pilot period, to inform any future decision regarding permanent implementation or expansion.
Approval And Authorisation
Screened By: Car Parks & Concessionary Trading Manager
Date: 23/06/2026
Approved By: Director of Environmental Services
Date: 23/06/2026