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1. IntroductionThe National Consultative Committee on Racism and Interculturalism was established by the Department of Justice, Equality and Law Reform in 1998 and is a partnership of government departments, agencies and non-government organisations. The Committee was set up to advise the Government with regard to racism in Ireland and responses to it. In particular, the Committee is to support the continuation of integrated strategic initiatives to address racism and promote interculturalism already commenced during the European Year Against Racism (1997). The work of Committee builds on the activities commenced by the Irish National Co-ordinating Committee of European Year Against Racism, which represented the beginning of a process towards increasing co-operation at both national and European levels in the fight against racism. One important activity undertaken in 1997 by the latter Committee, was the development, in co-operation with the Strategic Management Initiative (SMI) Sub-Group on Quality Customer Service, of a series of briefing papers to feed a relevant anti-racist dimension into the Customer Action Plans being developed by each government department. In drawing up the briefing papers, the main focus was on those Government departments whose operations are likely to have the most obvious impact on Black and minority ethnic groups. These were the Departments of: Justice, Equality and Law Reform; Environment (including Travellers) and Local Government; Social Community and Family Affairs; Education and Science; Health and Children; Enterprise, Trade and Employment; the Taoiseach, and Foreign Affairs. The briefing papers, which were submitted to each department, were intended to firstly resource each government department in preparing its Customer Action Plan, and to secondly resource the SMI Sub-group in its review of the plans as they were developed and implemented. To continue this support work in the context of the SMI, the following paper has been prepared by the National Consultative Committee to review the progress made in incorporating an anti-racist dimension in the Customer Action Plans which have now been prepared by each of the above departments. The paper begins with an overview of the key elements of the Department of the Taoiseach guidelines for the production of the Customer Actions Plans as they are relevant to Black and minority ethnic groups and sets out the core issues common across briefing papers drawn up in 1997. It then examines the published Customer Action Plans, measuring their approach against the briefing papers submitted and relevant parts of the Department of the Taoiseach Guidelines. Following this, the paper examines the broader Strategy Statements of each department, exploring the quality of any focus identified in terms of Black and minority ethnic groups and identifying gaps or potential for such a focus where these exist. From this, the final section outlines a set of recommendations to the SMI Committee responsible for reviewing the Customer Action Plans so that the anti-racist dimension of the plans can be expanded and deepened. 
2. Goverment Guidelines on planning for quality customer serviceFollowing the formal publication of the Principles of Quality Customer Service in May 1997, the SMI Quality Customer Service and Front-line Groups prepared a set of guidelines to assist Government Departments in preparing their Customer Action Plan. These guidelines identified a number of key elements to be covered in the plans including identification of customers, management and training requirements, provision for consultation and the establishment of monitoring arrangements and related performance indicators. Using each of these elements as a guide, a briefing paper was drawn up by the Irish National Co-ordinating Committee for the European Year Against Racism in 1997 for each of the government departments outlined in the introduction on how an anti-racist dimension could most effectively be developed within each Customer Action Plan. These briefing papers are summarised as follows - the key elements of the governments guidelines for the production of the Customer Action Plans are quoted in bold, followed in each case by a summary of how these elements could be adapted or expanded to include an effective anti-racist dimension in the operations of each department. "In developing a Quality Customer Service ethos it is useful to bear in mind that there are only two types of people working in any organisation: those who deal directly with the customers, and those who support somebody in the organisation who deals directly with the customers" (Guidelines for Quality Customer service. 1997) Although each of the departments for which briefing papers were prepared have overall responsibility for the services provided under their remit, most, with the exception of the Department of Social, Community and Family Affairs, provide only a limited range of services directly to the public. However, defining their customers as simply those using or affected by services provided directly by the department appeared to unduly restrict the application of the Customer Action Plan having regard to the overall remit of each department. The briefing papers acknowledged that Customer Action Plans for intermediary state agencies would be developed in the second phase of the Quality Customer Service Initiative. However, it was considered that by defining their customers as all those using or affected by all the services under their overall responsibility, the Customer Action Plan provided a valuable opportunity for each department to develop a broad framework for delivering services to the end user which could then be used and applied in more operational detail by the intermediary agencies under their aegis. It was also noted however, that many departments did also provide services directly to the public which have considerable potential for addressing racism. "An essential first step [in the preparation of Customer Action Plans] is for each Government Departments to identify its own customers and clients and, where necessary, to segment customers in accordance with the type of services provided for them. Segmentation it states, is necessary in order to focus on the different customer groups and their particular requirements. ''(Guidelines for Quality Customer Service, 1997) This provision was considered to be particularly relevant to building an racist dimension into Customer Action Plans given the limited information that exists on Black and minority ethnic groups (including Travellers) and the particular needs of such groups in relation to state services. Disaggregation of data by Departments along ethnic lines is essential to inform policy making and the design of provision. The collection of comprehensive data on the needs, experiences and circumstances of Black and minority ethnic groups is essential to securing outcomes from policy and provision for these groups. "In their dealings with the public, Civil Service Departments and Offices will provide a structured approach to meaningful consultation with, and participation by, the customer in relation to the development, delivery and review of services". (Guidelines for Quality Customer Service, 1997) In line with this principle, an effective mechanism for ensuring that the needs of Black and minority ethnic groups can be taken on board on an on-going basis would be a clear commitment by each department to include representative organisations of these groups in the consultation and participation structures to be established within the framework of the Customer Action Plans. "Training is an essential element for ensuring the success of any change of management process…. The rights of minorities should [also] be addressed through the provision of appropriate training…When it comes to customer service training, a 'partnership' approach is recommended which takes account of the needs and expectations of customers, staff and management. Customer groups should, where possible, be involved in the design of training programmes for front-line staff". (Guidelines for Quality Customer Service, 1997) The provision of training to staff in each Department and their intermediary agencies that includes anti-racist modules has a crucial contribution to make in relation to the quality of services for Black and minority ethnic groups. In this respect, it was considered important for Customer Action Plans to commit each Department to the provision of anti-racist modules within in-service training for staff at all levels. To ensure the relevance of this training it would be important to involve Black and minority ethnic group organisations in its design and implementation. The training could provide:
"Customer Service training cannot be viewed in isolation and must be seen within the context of the organisation culture and value system. Training programmes delivered in an organisation which has not established the necessary supportive culture will have limited success and very little long-term impact". A clear demonstration of equal treatment in the provision of state services (a specific goal of the Customer Action Plans) would be a commitment of senior management in each department to the preparation, application and dissemination of an equal status policy statement as part of the Quality Customer Service approach. This statement would commit each department to:
To emphasise the commitment of each department to their Equal Status Policy, it would be important that a member of senior management be given responsibility for the implementation and monitoring of the policy. The adoption by each Department of an Equal Status Policy will be an important element in encouraging the development of a culture and environment which can support effective anti-racist measures and programmes to meet the needs of Black and other minority ethnic groups in the areas in which they have ultimate responsibility. "In their dealings with the public, Civil Service Departments and Offices will establish a well publicised, accessible, transparent and simple to use system of dealing with complaints". Systems for dealing with complaints established by each department and its intermediary agencies should include experiences of racism as a justifiable category of complaint. This should be well publicised, and to ensure accessibility, include the publication of information in languages appropriate to the department's customer base. "To ensure consistent delivery of high quality service in any organisation it is necessary to establish measurable standards and indicators by which performance can be assessed on an on-going basis" In order to monitor and evaluate the anti-racist dimension of the Customer Action Plan, it will be important to include this in the evaluation framework from the outset. This should include identifying the information which will be required to assess the impact of policies on Black and minority ethnic groups.
3. Review of Customer Action PlansCustomer Action Plans have been completed and published by all government departments since the submission of the briefing papers in mid 1997. In addressing the quality of service, the Plans focus primarily on contact between departments and their customers - quality in this respect being largely defined in relation to timeliness and courtesy in telephone and written communications, access to and comfort of public offices and clarity and comprehensiveness of information provided. A commitment to the development of complaints procedures and to the provision of a framework for consultation with the customer base is also specified in each plan. While these provisions in some ways reflect the main elements specified in the Guidelines for the Customer Action Plans, a number of gaps and limitations are apparent when the plans are reviewed with reference to the guidelines and the briefing papers on anti-racism outlined above. In particular:
4. Departmental Strategy StatementsAs noted in the previous section, the Quality Customer Services Initiative comprises only one part of the Strategic Management Initiative (SMI) and thus has limitations in terms of the extent to which it can provide an overall basis for measures to adequately address racism and provide for services that specifically meet the needs and circumstances of Black and other minority ethnic groups. Given this, it is useful to consider the SMI Strategy Statements produced by each department to assess the extent to which a focus has been identified in relation to black and minority ethnic groups and the potential for the overall SMI to complement and enhance the anti-racist focus of Government Departments. In doing this, SMI Statements of Strategy for each department focused on in this paper are reviewed individually as follows. 4.1 Department of Education and Science With the exception of the Traveller Community, the SMI Statement of Strategy of the Department of Education and Science does not specifically refer to minority ethnic groups. However, the strategic challenges the department identifies for itself are clearly relevant to such groups, including;
In meeting these challenges the Department has placed a particular focus on tackling education disadvantage and states that the principles underpinning the National Anti-Poverty Strategy (NAPS) are reflected in the goals, objectives and activities of its Strategy Statement. This approach is very important from an anti-racist perspective given that Travellers and other minority ethnic groups have been identified by NAPS as being in persistent poverty or known to be at risk of poverty. As one of the primary objectives of NAPS is to address inequalities which might lead to poverty among such groups, the SMI Statement provides some form of a basis for combating inequalities arising from racism through the education system. However, it needs to be more explicit in this regard. The SMI Statement could be further elaborated through committing the Department to the preparation of an Equal Status Policy. The Policy should set clear targets for meeting the educational needs of Black and minority ethnic groups, which should be set out in the Goals/High Level Objectives section of the SMI. It should also set out time-scales for the achievement of these targets and identify appropriate measures under each of the key departmental services identified in the SMI Statement for their implementation. The Department of Education and Science has involved a range of interests in the development of education policy and in the implementation of education services. The SMI Statement recognises a range of groups as 'partners in education' including 'organisations focusing on the educational needs and interests of particular groups in our society such as people with disabilities, people who are unemployed, members of the Travelling community and others'. This important commitment to partnership could usefully be further expanded to include the organisations of all Black and minority ethnic groups. Further, specific institutional mechanisms to realise this partnership should be identified. 4.2 Department of Enterprise, Trade and Employment The Customer Action Plan of the Department of Enterprise, Trade and Employment, as referred to above, explicitly commits the Department to equal treatment of all clients and to ensuring there shall be no discrimination on the basis of, inter alia, a person's colour or ethnic origin. The SMI Statement of the Department does not explicitly refer to Black and minority ethnic groups. However, it does state that one of its overall business goals will be "to promote fairness and efficiency in the labour market thereby maximising the welfare of workers and promoting social inclusion". The specific objectives and associated actions set out by the Department in the SMI Statement to achieve this strategic goal require explicit reference to racism and the needs of Black and minority ethnic groups. Such explicit reference could usefully include commitments by the Department to:
4.3 Department of Health and Children Chapter six of the Strategy Statement of the Department of Health and Children sets out the divisional objectives of the Department and the steps to achieving them. Under the heading of Disability Services and Services for Travellers, it states the objective of achieving "…improved health status in the Travelling Community by measures designed to increase their level of take-up of services". Actions to be taken to help achieve this objective include the appointment of a "Traveller Health Advisory Committee to include Traveller interests" and the publication of a "policy statement on Travellers Health". Other than the particular objectives and actions relating to Travellers, the Strategy Statement contains no other specific references to racism or the particular health needs of other minority ethnic groups. However, the Statement does refer to "equity" as being one of the high level objectives of the Department and the policies and measures already developed in line with this objective (such as the special measures for Travellers) do provide useful pointers as to how the application of the principle of equity could be expanded to meet the needs of Black and other minority ethnic groups in general. The absence of any specific reference to racism or the particular health needs of minority ethnic groups, other than Travellers, in general gives cause for concern however, as failure to name issues or groups in policy or strategic statements can lead to the exclusion of these issues or groups in practice. For example, in noting the necessity of the health strategy to take on board the implications of the changing demographic profile of the population, no mention is made of increasing numbers of refugees and asylum seekers coming into Ireland. These groups form a significant client group of health board services and the particular issues affecting them (including the health implications of racism) have not been the subject of any systematic response. An important means by which these issues and needs could be taken aboard in the key areas of policy and service provision outlined in the Strategy Statement would be to elaborate on what is precisely meant by the objective of equity which is headlined at the beginning of the Statement. This could be done by referring to existing and proposed equality legislation and the National Anti-Poverty Strategy (NAPS), which explicitly name the groups most affected by or vulnerable to inequality. An effective Equal Status Policy for the health services could then be developed and implemented by referring to Black and minority ethnic groups in the various strategic aims, policies and actions outlined in the Strategy Statement. 4.4 Department of Social, Community and Family Affairs The Strategy Statement of the Department of Social, Community and Family Affairs has only one specific reference to minority ethnic groups. This is contained in the section on 'Policy Development and the Evolving Role of the Department', where it is stated that the Department will encourage and promote the provision of opportunities for those groups within the community which have had difficulties accessing the labour market in the past, including, inter alia, 'members of the travelling community' (DSCFA, 1998: 16). Key policy commitments contained in the strategy however, can be seen as being at least implicitly inclusive of Black and other ethnic minorities. Particularly important in this respect is the commitment by the Department to pursuing the goals of the National Anti-Poverty Strategy (NAPS). The Guidelines for Policy Proofing in the Context of the National Anti-Poverty Strategy (P2000/98/40) states that the focus of NAPS should be on "poverty proofing and inequalities in so far as they are likely to lead to poverty". Poverty proofing, the Guidelines state, "should focus on those groups which have been identified as being either in persistent poverty or known to be at risk of poverty in both urban and rural areas" including, inter alia, "members of the Travelling community" and "ethnic minorities". The Statement also identifies a set of core values in its dealings with its customers including "fairness and courtesy". Although it is not specified precisely what is meant by these terms in the Strategy Statement itself, the Department's Customer Action Plan (as referred to above) does state that services will be provided in a way that respects the rights of all minorities and provides for anti-racism modules in proposed staff training. The absence of explicit reference to racism or the specific needs and circumstances of Black and minority ethnic groups in the Strategy Statement gives cause for concern however, as failure to mention specific groups in policy or strategic terms can lead to their exclusion in practice. The Statement does not, for example, refer to racism as an issue with respect to policies and actions to improve take-up of training and employment opportunities, nor is it mentioned as a potential issue with respect to the provision of welfare services. A better approach would be that adopted in the Department's Customer Action Plan which, as stated, includes a brief equality statement that specifically identifies racism as an issue and the need to tackle this form of discriminatory practice in the delivery of services. The inclusion of such a provision in the Strategy Statement would have a wider impact than the Customer Action Plan as the Statement covers policy development as well as the quality of service delivery. The issue of racism and the particular experiences of Black and minority ethnic groups should be explicitly provided for in key actions contained in the Strategy including:
4.5 Department of the Environment and Local Government Travellers and other minority ethnic groups are briefly referred to in the Statement of Strategy of the Department of the Environment and Local Government under the section on housing. Here the Statement says that "a significant increase in resources for social housing generally has been made available and greater attention is being paid to special needs such as those of the homeless, travellers, and the disabled".. The section on housing goes on to state that the Department "works with the Department of Justice, Equality and Law Reform in relation to general issues regarding travellers, landlord and tenant matters and asylum seekers and refugees". The statement does not however refer to what these "general issues" include. In relation to the broader strategy, policy commitments contained in the statement, do not explicitly refer to minority ethnic groups. However, some commitments can be seen as being at least implicitly inclusive of such minorities. Important in this respect is the "underlying goal" of seeking to optimise economic and social progress through the department's role in areas such as infrastructure, service provision and the regulatory process. Elaborating on this, the statement refers to the key aspects of social and economic progress identified in An Action Programme for the Millennium - "maximising the long-term potential for employment, social inclusion and living standards [our italics]". The absence of more explicit reference to ethnic minorities in the specific strategies outlined in the Statement does give cause for concern however. This is especially notable in relation to housing where, despite the reference to Travellers and asylum seekers outlined above, key strategies such as support for social housing or the private rented sector do not refer to racism as a possible barrier to access or as a discriminatory practice likely to reduce the quality of a person's living environment. With regard to the private rented sector for example, the Strategy Statement states that the Department will "develop and maintain a framework for an efficient private rented sector as an essential part of the housing system". Racism is not identified as an issue that might inhibit the 'efficient' operation of this system, nor is it referred to as an issue that would be examined in the regulatory regime for the sector to be operated by the local authorities. The absence of any explicit reference to racism in this respect is notable given the emerging evidence of extensive discrimination against Black and minority ethnic groups in the provision of private rented sector accommodation and its identification as a causal factor in homelessness. 4.6 Department of the Taoiseach There is no specific reference to Black and minority ethnic groups in the Strategy Statement of the Department of the Taoiseach. However, the Statement does refer to the promotion of equity as being one of the major goals of the Department. A key mechanism for the achievement of this goal is the Department's role in the maintenance and development of social partnership. In setting out the main challenges for the Department the Statement refers to the Action Programme for the Millennium and Partnership 2000 each of which, it notes, "place a high priority on promoting greater social equity and combating poverty through tax reform and an extensive programme of action on social exclusion within the framework of the National Anti-Poverty Strategy". This commitment to the National Anti-Poverty Strategy (NAPS) and the leadership role played by the Department of the Taoiseach, both within the public sector and through the social partnership process, provides an important basis for tackling racism and for meeting the needs of minority ethnic groups. The issue of racism and the particular experiences of minority ethnic groups should, therefore, be explicitly provided for in key actions contained in the Strategy including;
4.7 Department of Foreign Affairs The only explicit reference to racism in the Strategy Statement of the Department of Foreign Affairs is in the section on Human Rights. One of the stated actions in seeking to ensure that human rights are accorded a high priority in Irish foreign policy is the ratification of key international human rights instruments including the UN Convention on the Elimination of All Forms of Racial Discrimination. The role played by the Department nationally and internationally provide an important basis for tackling racism and for meeting the needs of minority ethnic groups. The issue of racism and the particular experiences of minority ethnic groups should, therefore, be explicitly provided for in key actions contained in the Strategy including:
4.8 Department of Justice, Equality and Law Reform The most explicit references to the issue of racism and to Black and minority ethnic groups in the Strategy Statement of the Department of Justice, Equality and Law Reform are contained in the section dealing with the equality functions previously under the remit of the Department of Equality and Law Reform. This section establishes the goal of "bringing about a more equal society, by outlawing discrimination and by facilitating equality of opportunity, especially for certain groups that have experienced disadvantage". In a footnote to this statement, it states that "the grounds on which discrimination will be prohibited under legislation are- gender, marital status, family status, sexual orientation, religion, age, disability, race and membership of the Traveller Community [our italics]". (DJELR, 1998: 52). To support this equality agenda, the Strategy Statement sets out a series of strategies and outputs, in addition to the equality legislation, to be implemented by the year 2000. Only two of these explicitly name Black and minority ethnic groups - a commitment to monitoring the implementation of the Report of the Task Force on the Travelling Community and ratification of the UN Convention on the Elimination of All Forms of Racial Discrimination. However, strategies and actions to promote equality in general, assuming that they make allowance for all the categories protected under existing and proposed legislation, will be of critical importance in addressing racism and promoting the inclusion of minority ethnic groups. Especially important in this respect is the role of the Department in developing an equality proofing framework within the National Anti-poverty Strategy to provide a mechanism for government departments to assess the impact of their policies on equality/inequality. Given the critical role of the Department in promoting equality within the state sector and in the wider society, there is surprisingly little reference to racism in the sections dealing with other areas of the Department's activities. This is particularly noticeable in the section on Immigration, Citizenship and Asylum services provided by the Department, where minority ethnic groups comprise a sizeable proportion of the total client group. Under this section, the Strategy Statement outlines the following objective: "Integrate into Irish society persons who have been recognised as refugees or have been given leave to remain in the State on humanitarian grounds". However, no mention is made of racism as a possible barrier to such integration nor of interculturalism as a key element of such integration. While it is stated that the Department will co-operate with other Departments and agencies to help achieve the objective of integration, no specific mention is made of how this might be achieved. Nor is it mentioned how strategies and measures being developed as part of the Department's equality brief could assist in this respect. The Strategy Statement also sets down specific provisions for improving the quality of immigration, citizenship and asylum processing services, including the enhancement of information provision and staff training. With regard to the latter, the potential for racism or the need to develop a capacity to meet the needs of a multi-ethnic customer base are not mentioned as relevant issues to be included in staff training. Neither is it stated how information provision is to be improved in line with consumer needs - for example, it is not specified whether such improvements will be linked to research on consumer needs or whether, as envisaged in the Customer Actions Plans, specific customer panels are to be set up to inform the quality improvement process in this area. Despite these limitations, the Strategy Statement and the Department's role in bringing forward and implementing the equality agenda at national level do still provide a valuable basis for addressing racism and promoting the inclusion of Black and minority ethnic groups both in terms of the internal operations of Department itself and wider afield. However, with regard to the Department functions in promoting equality, all policies, programmes and measures should specify the groups, as set down in equality legislation, to which the general term of 'equality' is to cover. Failure to mention a specific group in policy terms can often mean that the group in question is excluded in practice. This is evidenced by the Department's own Strategy Statement where a broad commitment to promoting equality has not been translated into specific measures to address racism in relevant services provided by the Department. The Department could also play a role in promoting equality within the state sector through the SMI itself.
5. Conclusion and ReccommendationsIt is clear from this review that the Customer Action Plans studied fall significantly short of what was proposed in the guidelines developed by the Quality Customer Service Sub-Group. This is particularly true where these guidelines seek to have a focus on the rights of minorities in the Customer Action Plans through promoting "the provision of appropriate training" and linking this to a "necessary supportive culture" within Government Departments. It is important that the current review of the Customer Action Plans and the further expansion of the Quality Customer Service approach beyond Government Departments would address this deficiency. To this end it is recommended that:
The Principles of Quality Customer Service published in May 1997 make particular mention of the rights of minorities. The principles included that of "respect(ing) the rights of minorities at all times in the delivery of services". This principle is not reflected within the Customer Action Plans. It is recommended that Customer Action Plans would be required to include a named commitment to designing and implementing an intercultural dimension within policy making and service provision. This review raise questions as to the nature of the commitment and approach to equality within the Strategic Management Initiative. Such a concern was suggested by the National Economic and Social Forum in its opinion Partnership 2000: Development of the Equality Provisions which stated that "equality should be an explicit principle underlying the Strategic Management Initiative as a whole". This review clarifies that equality from an anti-racist and intercultural perspective is not adequately emphasised by the SMI. This is particularly evident from the Departmental Strategy Statements. This is a contradiction of the equality framework committed to in Partnership 2000 which embraces not only women and people with a disability but also Travellers and, more recently, other minority ethnic groups. It is important that this deficiency is rectified. To this end it is recommended that:
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