Publication - Impact assessment

Coronavirus (COVID-19) domestic vaccine certification: equality impact assessment

Published: 15 Nov 2021

Equality impact assessment (EQIA) considering positive and negative differential impacts that the domestic Covid Vaccine Certification scheme may have on the nine characteristics protected under the Equality Act 2010.

Coronavirus (COVID-19) domestic vaccine certification: equality impact assessment
Assessing the impacts and identifying opportunities to promote equality

Assessing the impacts and identifying opportunities to promote equality

Do you think that the policy impacts on people because of their age?

Age

Positive

Negative

None

Reasons for your decision

Eliminating unlawful discrimination, harassment and victimisation

 

X

 

There is some evidence of negative differential impacts identified at this time.

There is the potential for indirect discrimination of older people and care leavers (up to the age of 26) due to higher rates of digital exclusion and lack of photo ID within this demographic. The paper Certificate and helpline will mitigate against this.

Due to lower vaccination uptake among younger people, even though the policy does not apply to employment, there is a risk that Certification could be used as a condition of employment. This may have differential impacts on younger people.

We have published sectoral guidance to support effective implementation consistent with our policy aim, which can be found on the Scottish Government website. We recognise that some businesses, outside the regulated settings, are asking people for evidence they have been fully vaccinated as a condition of entry or as a condition of employment. We emphasised in our guidance that businesses which are not covered by the Government's scheme need to consider carefully their obligations under all relevant law including data protection, the Equality Act and Human rights. For more information see the Equality and Human Rights Commission Guidance for Employers.

All 16 and 17 year olds were invited to come forward for vaccination from 6 August.[99] A person is considered fully vaccinated once they have received two doses of the vaccine and 14 days has passed after receiving the final dose. 17 year olds who are turning 18 when Certification comes into force, who have not had time to be fully vaccinated, will be covered by the exemption for under 18s.

Certification may present practical problems for care leavers due to frequent changes in of postal address. We have set up a Resolver Team to resolve any issues relating to inaccuracies in vaccination records.

Advancing equality of opportunity

X

   

There is some evidence of a positive differential impact identified at this time.

If the policy objective is achieved and the risk of transmission is reduced, this will positively impact older people who have poorer health outcomes if they contract the virus.

Certification may support older people, who are more at risk if they contract the virus, to feel safer and more confident in society. This is important for wellbeing, mental health and maintaining relationships.

Promoting good relations among and between different age groups

X

   

As above, Certification may support older people, who are more at risk if they contract the virus, to feel safer and more confident in society. This is important for wellbeing, mental health and maintaining relationships.

Do you think that the policy impacts disabled people?

Disability

Positive

Negative

None

Reasons for your decision

Eliminating unlawful discrimination, harassment and victimisation

 

X

 

There is some evidence of negative differential impacts identified at this time.

There is the potential for indirect discrimination of disabled people due to higher rates of digital exclusion within this demographic. The paper Certificate and helpline will mitigate against this.

There will be exemptions to prevent indirect discrimination of people who may be medically unable to be vaccinated. The expectation is these numbers will be very small, for almost all disabled people or people with other medical conditions safe completion of immunisation, with support if required, is achievable.

Advancing equality of opportunity

X

   

There is some evidence of positive differential impacts identified at this time.

If the policy objective is achieved and the risk of transmission is reduced, this will positively impact disabled people who have poorer health outcomes if they contract the virus.

Promoting good relations among and between disabled and non-disabled people

X

   

There is some evidence of positive differential impacts identified at this time.

Certification may support disabled people, who are more at risk if they contract the virus, to feel safer and more confident in society. This is important for wellbeing, mental health and maintaining relationships.

Do you think your policy impacts on people proposing to undergo, undergoing, or who have undergone a process for the purpose of reassigning their sex?

(NB: the Equality Act 2010 uses the term 'transsexual people' but 'trans people' is more commonly used, although it may include a wide range of people not covered by the Act).

Gender reassignment

Positive

Negative

None

Reasons for your decision

Eliminating unlawful discrimination, harassment and victimisation

 

X

 

There is some evidence of negative differential impacts identified at this time.

Without mitigations, Certification could present practical barriers for some trans people due to data flow and interoperability issues. Individuals can create separate profiles on the App for international and domestic use by using different email addresses. If an individual wishes to use a different name domestically, and has photo ID in that name, they can create one account for international travel, which aligns with the details on their passport, and one account for domestic use, which aligns with their preferred name. We have established a Resolver Team to resolve any issues relating to inaccuracies in vaccination records.

Trans people are less likely to have ID and stakeholders have raised concerns that some biometric identification software contains gendered and racial biases. Jumio, the company providing the software, state that their software has equal rates of success across all demographics with a matching rate of over 95%. For the other 5% there will be a manual check by Jumio staff to verify the user's identity. For the limited number of people who cannot register using the App, they can access a paper copy of their Certificate by calling the helpline.

Advancing equality of opportunity

   

X

There is no evidence of a differential impact identified at this time.

Promoting good relations

X

   

There is some evidence of a positive differential impact identified at this time.

If the policy objective is achieved and higher risk settings are allowed to continue to operate as an alternative to closure or more restrictive measures, this, this will facilitate socialisation and help to reduce feelings of isolation, which is important to trans people's mental health and wellbeing.

Do you think the policy impacts on people because of their marriage or civil partnership?[2]

Marriage and Civil Partnership

Positive

Negative

None

Reasons for your decision

Eliminating unlawful discrimination, harassment and victimisation

   

X

There is no evidence of a differential impact identified at this time.

There will be an exception within the regulations for marriages and civil partnerships and associated celebrations.

Advancing equality of opportunity

   

X

There is no evidence of a differential impact identified at this time.

Promoting good relations

   

X

There is no evidence of a differential impact identified at this time.

Do you think that the policy impacts on women because of pregnancy and maternity?

Pregnancy and Maternity

Positive

Negative

None

Reasons for your decision

Eliminating unlawful discrimination, harassment and victimisation

 

X

 

There is some evidence of negative differential impacts identified at this time.

An Inclusive Vaccinations Programme, which includes targeted outreach for pregnant women, will help mitigate any risks that Certification indirectly discriminates pregnant women, who may be more inclined to be vaccine-hesitant.

Due to higher levels of vaccine hesitancy among pregnant women, even though the policy does not apply to employment, there is a risk that Certification could be used as a condition of employment. This may have differential impacts on pregnant women.

We have published sectoral guidance to support effective implementation consistent with our policy aim, which can be found on the Scottish Government website. We recognise that some businesses, outside the regulated settings, are asking people for evidence they have been fully vaccinated as a condition of entry or as a condition of employment. We emphasised in our guidance that businesses which are not covered by the Government's scheme need to consider carefully their obligations under all relevant law including data protection, the Equality Act and Human rights. For more information see the Equality and Human Rights Commission Guidance for Employers.

Advancing equality of opportunity

X

   

There is some evidence of positive differential impact identified at this time.

If the policy objective to reduce transmission and increase vaccine update is achieved, this could positively impact pregnant women, as there is evidence that they may be at an increased risk of becoming severely unwell compared to women who are not pregnant, particularly pregnant women in the third trimester.

Promoting good relations

X

   

There is some evidence of a differential positive impact identified at this time.

Evidence indicates women would feel more comfortable if Certification was in place in certain settings, and so Certification may support pregnant women to feel safer and more confident in society. This is important for wellbeing, mental health and maintaining relationships.

Do you think the policy impacts on people on the grounds of their race?

Race

Positive

Negative

None

Reasons for your decision

Eliminating unlawful discrimination, harassment and victimisation

 

X

 

There is some evidence of negative impacts identified at this time.

Lower levels of vaccination uptake are evident in minority ethnic groups. An Inclusive Vaccinations Programme, which includes targeted outreach for ME groups, will help mitigate any risks that Certification indirectly discriminates ME people who may be more inclined to be vaccine hesitant.

Evidence suggests that biometric identity software often contains gendered and racial biases. Jumio, the company providing the software, state that their software has equal rates of success across all demographics with a matching rate of over 95%. For the other 5% there will be a manual check by Jumio staff to verify the user's identity. For the limited of number of people who cannot register using the App, they can access a paper copy of their Certificate by calling the helpline.

ME groups are more likely to face digital exclusion. The paper Certificate and helpline with mitigate against this.

Due to lower vaccination uptake among ME groups, even though the policy does not apply to employment, there is a risk that Certification could be used as a condition of employment which may have differential impacts on ME people.

We have published sectoral guidance to support effective implementation consistent with our policy aim, which can be found on the Scottish Government website. We recognise that some businesses, outside the regulated settings, are asking people for evidence they have been fully vaccinated as a condition of entry or as a condition of employment. We emphasised in our guidance that businesses which are not covered by the Government's scheme need to consider carefully their obligations under all relevant law including data protection, the Equality Act and Human rights. For more information see the Equality and Human Rights Commission Guidance for Employers.

Advancing equality of opportunity

X

   

There is some evidence of positive differential impact identified at this time.

If the policy objectives to reduce transmission and increase vaccination uptake are achieved, this will positively impact ME communities, who have poorer health outcomes if they contract the virus.

Promoting good race relations

   

X

There is some evidence of positive differential impact identified at this time.

If the policy objectives are achieved, with increased vaccine uptake and higher risk settings continuing to operate as an alternative to closure or more restrictive measures, this will facilitate socialisation and could support mental health and wellbeing, which has been negatively impacted during the pandemic.

Do you think the policy impacts on people because of their religion or belief?

Religion or belief

Positive

Negative

None

Reasons for your decision

Eliminating unlawful discrimination, harassment and victimisation

 

X

 

There is some evidence of negative impacts identified at this time.

There may be some people who do not want to be vaccinated for reasons related to their religion or beliefs. An Inclusive Vaccinations Programme, which includes targeted outreach, will help mitigate any risks that Certification indirectly discriminates people who may be more inclined to be vaccine-hesitant based on their religion or beliefs.

Advancing equality of opportunity

   

X

There is no evidence of a differential impact identified at this time.

There will be exceptions for premises being used for certain purposes, including worship.

Promoting good relations

   

X

There is no evidence of a differential impact identified at this time.

There will be exceptions for premises being used for certain purposes, including worship.

Do you think that the policy impacts on men and women in different ways?

Sex

Positive

Negative

None

Reasons for your decision

Eliminating unlawful discrimination, harassment and victimisation

 

X

 

There is some evidence of negative differential impacts identified at this time.

Women have higher rates of vaccine hesitancy than men. An Inclusive Vaccinations Programme, which includes targeted outreach to women, will help mitigate any risks that Certification indirectly discriminates women who are more likely to be vaccine hesitant.

Lower levels of vaccination uptake are evident among women. Even though the policy does not apply to employment, there is a risk that Certification could be used as a condition of employment which may have differential impacts on women.

We have published sectoral guidance to support effective implementation consistent with our policy aim, which can be found on the Scottish Government website. We recognise that some businesses, outside the regulated settings, are asking people for evidence they have been fully vaccinated as a condition of entry or as a condition of employment. We emphasised in our guidance that businesses which are not covered by the Government's scheme need to consider carefully their obligations under all relevant law including data protection, the Equality Act and Human rights. For more information see the Equality and Human Rights Commission Guidance for Employers.

Advancing equality of opportunity

X

   

There is some evidence of positive differential impact identified at this time.

If the policy objective is achieved and the risk of transmission is reduced, this will positively impact men, who have poorer health outcomes if they contract the virus.

Evidence indicates women would feel more comfortable if Certification was in place in certain settings and so Certification may support women to feel safer and more confident in society. This is important for wellbeing, mental health and maintaining relationships.

Promoting good relations between men and women

X

   

There is some evidence of positive differential impact identified at this time.

If the policy objective is achieved and higher risk settings can to continue to operate as an alternative to closure or more restrictive measures, this will facilitate socialisation and could support mental health and wellbeing of both sexes.

Do you think that the policy impacts on people because of their sexual orientation?

Sexual orientation

Positive

Negative

None

Reasons for your decision

Eliminating unlawful discrimination, harassment and victimisation

 

X

 

There is some evidence of negative impacts identified at this time.

LGBQ+ people are less likely to have ID and stakeholders have raised concerns that some biometric identification software contains gendered and racial biases. Jumio, the company providing the software, state that their software has equal rates of success across all demographics with a matching rate of over 95%. For the other 5% there will be a manual check by Jumio staff to verify the user's identity. For the limited of number of people who cannot register using the App, they can access a paper copy of their Certificate by calling the helpline.

There is anecdotal evidence that people living with HIV may be slightly vaccine hesitant than the general population. An Inclusive Vaccinations Programme, which includes targeted outreach to people living with HIV, will help mitigate any risks that Certification indirectly discriminates people living with HIV who may be more likely to be vaccine hesitant.

Advancing equality of opportunity

X

   

There is some evidence of positive differential impacts identified at this time.

If the policy objective is achieved and the risk of transmission is reduced, this would benefit people living with HIV as they are more likely to have poorer outcomes if they contract Covid.

Promoting good relations

X

   

There is some evidence of a differential positive impact identified at this time.

If the policy objective is achieved and higher risk settings can to continue to operate as an alternative to closure or more restrictive measures, this will facilitate socialisation and could support mental health and wellbeing, which is particularly important for LGBQ+ older people, who report higher levels of loneliness.


Contact

Email: covid19-certificationhub@gov.scot