The Health Protection (Coronavirus) (Requirements) (Scotland) Amendment Regulations 2022 and The Health Protection (Coronavirus) (Requirements) (Scotland) Amendment (No. 2) Regulations 2022: equality impact assessment

This equality impact assessment (EQIA) is to analyse the potential impacts for each protected characteristic under the Equality Act 2010 of amending the definition of fully vaccinated to include the requirement for a booster if a primary course of MHRA vaccine was over 120 days ago and amend the definition of late night venue.

Age: Older People


Older people have been particularly impacted by the health harms of the virus. As seen in Figure 1, death rates calculated with data throughout the pandemic increase exponentially with age.

Covid-19 related death rates (deaths per 100,000 people)
Age Number of Deaths
Under 1 Year 1
1-4 0
5-9 1
10-14 1
15-19 4
20-24 4
25-29 8
30-34 18
35-39 41
40-44 63
45-49 139
50-54 251
55-59 379
60-64 620
65-69 778
70-74 1349
75-79 1675
80-84 2217
85-89 2407
90+ 2254

Figure 1. Death rates where COVID-19 was the underlying cause (per 100,000 people) Mar 2020 - Nov 2021. Source: Archive | National Records of Scotland ( (Deaths involving coronavirus (COVID-19) in Scotland - Week 49 - Table 5).[94]

There is a higher ratio of women to men in older age groups, reflecting women's longer life expectancy. For example, women make up 64% of people aged 85+ in Scotland.[95] Measures that may help limit the spread of coronavirus are designed to positively affect the entire population, but may particularly benefit older individuals.

Social isolation and loneliness has been exacerbated by Covid restrictions and a key group affected are those aged over 75. A report from Age UK from 6 months into the pandemic suggests that the pandemic has had a damaging effect on older people's mental health: 34% of those surveyed agreed that their anxiety was worse or much worse than before the start of the pandemic. Of those surveyed aged over 70, 31% reported feeling unsafe or very unsafe, and 45% uncomfortable or very uncomfortable when outside of their home due to the pandemic.[96]

More recent Scottish polling conducted in October 2021 also found 68% of respondents aged 75 or over felt 'worried about the Coronavirus situation' compared to 53% of all respondents (although small base size is noted for the over 75 group).[97]

In February 2021 Age UK conducted a survey on those aged 60+ showing that: 36% feel more anxious since the start of the pandemic and 43% feel less motivated do the things they enjoy since the start of the pandemic. Older people have reported losing confidence in their ability to take part in activities which were previously routine before the pandemic.[98] In addition the prolonged periods of isolation, reduced social contact, and limited mental stimulation has led to 22% of older people finding it harder to remember things since the start of the pandemic.

There have been significant wider impacts on older people. In March 2020, about 180,000 individuals (3% of the Scottish population) who were clinically extremely vulnerable (CEV) were asked to shield. CEV individuals are more likely to be female, older, and live in more deprived areas of Scotland than the population at large.[99] A study on the experience of those shielding found that 87% reported a negative impact to their quality of life, 85% a negative impact on physical activity and 72% a negative impact on their mental health.[100] A further Scottish survey conducted on the impacts of the second lockdown on those aged over 50 found 48% of respondents who had shielded 'felt more anxious' as they entered lockdown in January 2021, compared to 39% of all respondents.[101]

Differential impacts

Positive impacts

If the policy objective to reduce the risk of transmission are achieved this would positively impact older people, as any reduction in transmission of the virus will positively impact this group who are at a far higher risk of poorer health outcomes if they contract the virus.

Age Scotland suggested that Covid Status Certification could play a positive role in supporting older people to feel safer and more confident in society if they know that those around them are vaccinated or tested. This is particularly the case for those older people who are clinically extremely vulnerable. Age Scotland also felt that the introduction of testing was a positive addition to the Scheme.

Lockdowns and restrictions have negatively impacted older people's mental health and wellbeing. If the policy objective is achieved and higher risk settings continue to operate as an alternative to closure or more restrictive measures, this could positively impact older people if, for example, they are still able to attend the settings in scope with family, friends and support groups and services.

Negative impacts

During engagement with stakeholders earlier in the pandemic, it was thought that some older people and disabled people could find it difficult to understand instructions and administer a home test correctly. An increased proportion of older people may also experience fine motor difficulties—for example, following a stroke or for those living with Parkinson's disease—which may impact on their ability to utilise home testing kits effectively.[102]

Home test results being sent to mobile phones or an email address may also exclude some older people. Digital access reduces with age. As of 2019, 20% of over-55s in the UK do not own a smartphone[103] and only 47% of adults aged 75+ use a smartphone to access the internet, compared to 98% of 16-24 year olds.[104] 36% of households where all adults are over 65 do not have home internet access, with only 57% of those with access using it regularly. 60% of households where all adults are over 80 do not have internet access, with 72% not using it regularly. Only 29% of adults aged 75 and over use a smartphone to access the internet.[105]

The proportion of households in Scotland with internet access was at a record high of 88 per cent in 2019, broadly in line with the prior year (87 per cent).[106] Household internet access increased with net annual household income. Home internet access for households with a net annual income of £10,000 or less was 65 per cent in 2019, compared with almost all households (99 per cent) with a net annual income of over £40,000. Access differed by area of deprivation: 82 per cent of households in the 20% most deprived areas in Scotland had internet access at home compared with 96 per cent of households in the 20% least deprived areas. The percentage of adults who do not use the internet was higher for those living in the 20% most deprived areas than for those in the 20% least deprived areas in Scotland. Internet use also increased with income. Internet access also varied by tenure: 79 per cent of those in social rented housing had internet access compared with 91 per cent of households who owned their home.

Seventy-one per cent of adults who have some form of limiting long-term physical or mental health condition or illness reported using the internet, lower than for those who have some form of non-limiting condition or illness (90 per cent) and those who have none (94 per cent).[107]

Almost all (97 per cent) adults who use the internet access it at home, followed by 58 per cent who access the internet on the move using a mobile phone or tablet. The proportion of internet users reporting that they access the internet using a smartphone increased from 81 per cent in 2018 to 86 per cent in 2019. The proportion of internet users using a smartphone to go online was greater than the proportion who accessed the internet using a PC or laptop (72 per cent). Younger internet users were more likely to access the internet using a smartphone than older users, with 98 per cent of 16-24 year olds using smartphones compared with 47 per cent of adults aged 75+ (an increase from 29 per cent in 2018). Older internet users were more likely than younger users to use a tablet to access the internet. Of those who do not use the internet, the most common reason that could convince people to go online was keeping in touch with family and friends at no extra cost, however this was only reported by eight per cent of this group[108].

Covid Status Certification is available both digitally (via an App) and as a paper document. Stakeholders have highlighted that although paper Covid Status Certification would mitigate against digital exclusion, it may still present challenges depending on how easy it is to update (for instance if data is incorrect or out of date, such as QR codes expiring) and on what happens when a Certificate is lost, stolen or destroyed. Age Scotland noted that not all smart phones or camera phones can host the App. They also encouraged continued communications with business to ensure that the sector are aware of and accept paper Certificates.

However, people do not need to have a smart phone or tablet to display their negative test result, as any mobile phone that can receive text messages or access emails is sufficient. If they do not have access to a mobile phone or tablet, individuals will be able to print off their test results at home, or have someone display their test result for them using a mobile phone.

However, this may not be suitable for a variety of reasons, as many of those without a mobile phone may also not have a home computer or a printer available. Those without a printer could use public printing facilities such as libraries or print shops, but using these every time a test result is needed could be time consuming and costly, especially if a result is needed quickly outside of opening hours. This may also be problematic in rural areas which may have limited access to such facilities. Allowing another person to display a result on their behalf may then be a more suitable mitigation, but could also reduce older people's ability to access spaces in scope independently. However, as a very high percentage of older people are fully vaccinated, there may be only a small number of people who this affects.

If someone had no internet access but does have a standard (non-smart) mobile phone they can call 119 who will log their result through the portal for them and the text message will be received in the normal way.

For those unable to test themselves, self-test LFD kits can be administered by others (such as a family member, friend, or carer) who can also register the result on behalf of the person they tested if they are also unable to do so. For those unable to display their test results (such as people who do not have a mobile phone) when registering their result they could have it sent to another person's phone, who could then show the result on their behalf.

When registering on the App for the first time, the user needs to verify their identity before they can access their health records. This will done using biometric identity verification: a facial recognition software which will compare the photo in a person's ID document with a live photo or video. Stakeholders raised this as a potential issue, as some older people have never had ID, or it has expired and not been renewed. Stakeholders cited research commissioned by the Cabinet Office for the introduction of mandatory photo ID at polling stations, which suggests that 2% of people aged over 70 in Great Britain do not have any form of ID.[109]

However, those who cannot verify their identity on the App can call the free national helpline and request a paper copy of their Certification, or use the Covid Vaccination and Scheduling Portal. The Covid-19 Status Helpline is free and open every day from 10:00-18:00. A Resolver Group has also been established to resolve any reported inaccuracies in vaccination records and wider issues relating to acquiring Covid Vaccination Certification.

Stakeholders have also raised that clear, accessible communications are required as some older people may not be aware that a venue or event requires Certification, which may result in them being denied entry. Documents explaining what is shown on your Certificate have been translated into 19 different languages, and is also available in audio format, Easy Read, and Braille.

As Covid Status Certification is required to access some settings, it could potentially be used as a method of coercive control, for example if an abuser takes a phone or paper Certificate from the victim. Although older people have historically been a 'hidden' group in domestic abuse statistics, UK research from 2016 suggests that victims aged 61+ are much more likely to experience abuse from a family member, much more likely to suffer abuse from a current intimate partner and more likely to keep living with the perpetrator after getting support.[110]

Lastly, some older people rely on carers and others, including family members, for everyday living. If someone who cares for an older person does not have Certification, this could negatively impact on the older person if they are not able to access the setting in scope due to not having support from their carer. The inclusion of testing will act as a mitigation against this. However, the carer may also choose not to be tested.



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