Information regarding the implementation of Covid-19 passports: FOI release

Information request and response under the Freedom of Information (Scotland) Act 2002

Information requested

(a) Any scientific, medical, immunological or epidemiological evidence provided to Scottish Ministers that underpins or supports their decision to require vaccine passports for events consisting of more than 10,000 people at open air events such as football matches;

Advice/recommendations on how such a scheme would actually be implemented effectively, noting any practical or technical issues that could be foreseen or reasonably anticipated;

(c) Notes or records of any meetings/ consultations/ conversations/correspondence on the practicalities of the implementation of such a scheme with the SPFL, football clubs most concerned and supporter associations;

(d) Assessment of likely costs for those required to implement the vaccine passport scheme for events consisting of more than 10,000 people; and,

(e) Policy submissions/briefings to Ministers from civil servants and Special Advisers on the above topics, in particular those that immediately preceded the announcement by the First Minister to the Scottish Parliament.


(a) Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you.

The Coronavirus (COVID-19) vaccine certification: evidence paper is available here: Coronavirus (COVID-19) vaccine certification: evidence paper - (

(b) & (c) While our aim is to provide information whenever possible, in this instance the costs of locating, retrieving and providing the information requested would exceed the upper cost limit of £600. This is because initial searches of our systems indicate that there is a very large number of items which would be potentially within scope of your request, and which would require to be checked individually in order to determine whether they are in fact within scope. There is also a large number of officials who might reasonably be expected to have engaged in exchanges regarding vaccine passports and their introduction. Responding to this request would require me to ask those officials to search their personal mailboxes.

Under section 12 of FOISA public authorities are not required to comply with a request for information if the authority estimates that the cost of complying would exceed the upper cost limit, which is currently set at £600 by Regulations made under section 12.

You may, however, wish to consider reducing the scope of your request in order that the costs can be brought below £600.

(d) Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you.

The Domestic Covid Vaccine Certification – September 2021 – Business and Regulatory Impact Assessment is available here: The Health Protection (Coronavirus) (Requirements) (Scotland) Amendment (No. 2) Regulations 2021 (

(e) I have provided some of the information you have requested. An exemption under section 29(1)(a) of FOISA (formulation or development of government policy) applies to some of the information requested because it relates to the development of the Scottish Government’s policy on Covid vaccine certification.

This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption.

We have found that, on balance, the public interest lies in favour of upholding the exemption. We recognise that there is a public interest in disclosing information as part of open, transparent and accountable government, and to inform public debate. However, there is a greater public interest in high quality policy and decision-making, and in the properly considered implementation and development of policies and decisions.

This means that Ministers and officials need to be able to consider all available options and to debate those rigorously, to fully understand their possible implications. Their candour in doing so will be affected by their assessment of whether the discussions on Covid vaccine certification and public health relating to Covid transmission and outbreaks will be disclosed in the near future, when it may undermine or constrain the Government’s view on that policy while it is still under discussion and development.

The relevant documents are attached with the exemption applied to them.

About FOI
The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at

FOI202100240234 - Information released


Please quote the FOI reference
Central Enquiry Unit
Phone: 0300 244 4000

The Scottish Government
St Andrews House
Regent Road

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