Annex A - Progress with ERG Recommendations, as of July 2021
|Title||Recommendation||Intended action to be taken by May 2021 (as reported at December 2020)||Progress as of July 2021||Action Owner||Status|
|Systemic Issues and Risk COVID-19 Immediate Action|
|1. Emergency Sustenance Fund Payment||During COVID-19 BEMIS actioned emergency sustenance fund payments to ensure that Ethnic Minority families and individuals were able to access food, medicine, and other supplies regardless of their immigration status. However, the delivery of such a service by BEMIS is not sustainable. The Scottish Government should deliver an emergency sustenance fund using the existing infrastructure of state support for people and families across Scotland. This may involve using the Scottish benefits system creatively. The Scottish Government should ensure that any future COVID-19 response includes the learning and needs identified through the current programme.||We will seek to ensure action on this recommendation is reflected in our upcoming publication of the Anti-Destitution Strategy in the new year, which specifically addresses the particular circumstances faced by people who cannot access public funds.||In late 2020, we awarded a further £170,000 and in early 2021 £200,000 in funding to support those most acutely impacted minority ethnic communities in this uniquely challenging winter season. This was in addition to the £312,000 that was provided to minority ethnic families in the early weeks of the pandemic. The projects supported have supported expert organisations in offering mental health support, digital devices to enable people to stay connected with loved ones and curbing the harms of loneliness as well as frontline support to access food and medical supplies. A portion of this Fund has also supported our collective efforts to aid the vaccination programme, encourage up-take and also develop interactive resources in a variety of languages and dialects to ensure effective communication and engagement with the vaccination programme.||Equality, Inclusion & Human Rights||Completed|
|2. No Recourse to Public Funds||The No Recourse to Public Fund policy discriminates against minority ethnic communities and leaves children and families exceptionally exposed to COVID-19 social impacts: children are penalised for their parent’s nationality and situation. The Scottish Government and local authorities must ensure that any local lockdowns do not differentially impact on those subject to this discriminatory policy Accepting the reserved nature of the policy, the Scottish Government should review the nature of the No Recourse to Public Fund restrictions, and determine a localised strategy within those restrictions which can navigate how they can be overcome. Currently, the gaps in statutory service provision are patched up by the voluntary sector and volunteers. This cannot continue given the consequences of COVID-19, destitution and poor health.||In March 2021, the Scottish Government and COSLA published Ending Destitution Together, a strategy to improve support for people subject to NRPF living in Scotland). The strategy runs to 2024 and will be delivered through a partnership approach with the third sector, local authorities and public services, with the participation of people with lived experience. The strategy’s vision is that ‘No one in Scotland is forced into destitution and everyone has their human rights protected, regardless of their immigration status’, and its approach is based on the principles of prevention, partnership and personalisation. The strategy sets out a pathway to support people to find a way out of destitution and includes a range of actions to achieve this covering essential needs; advice and advocacy; and inclusion. It also recognises that, because NRPF policy is reserved to the UK Parliament, there are issues impacting people living in Scotland that the Scottish Government and COSLA cannot resolve and will need to continue to raise with the UK Government.||Equality, Inclusion & Human Rights||Ongoing|
|3. Test and Protect and Future Health Measures||There must be Minority Ethnic participation at all levels of the COVID response. It is also important to ensure that communication with individuals from minority ethnic communities by Test and Protect teams is effective and that Test and Protect teams have incorporated processes and expertise which reflect the diversity of the communities they serve and the intersectional framing of their experiences.||
||We have appointed dedicated resource in the Testing and Contract Tracing Policy Division in the Scottish Government to coordinate tackling inequalities within Test & Protect, to focus on action and improvement, and to apply this focus intersectionally. This lead is accountable to the Deputy Director, and is in regular contact with community groups such as BEMIS to ensure quality of action and community trust.
In addition, we have:
|Covid Public Health Directorate||Ongoing|
|Further, as other health policies, such as highest risk list and vaccinations, are being developed the Scottish Government must ensure that the needs of minority ethnic communities are considered and acted upon. There is a risk of undermining the broader zero COVID-19 community transmission approach if this is not done.||Not reported.||We are embedding inclusion as a key aspect of our national COVID-19 vaccination programme and future vaccination and immunisation programmes.
We have embedded inclusion into the vaccinations programme by:
|Vaccination Strategy & Policy Directorate|
||To ensure the needs of Minority Ethnic communities on the highest risk list (formerly shielding) are considered, we:
||Population Health Directorate|
|Culturally competent health promotion and disease prevention programmes, relating to issues such as the higher risk of diabetes and Cardio-Vascular Disease among South Asians, is well known but efforts to tackle it may have diminished recently and it is important that such efforts are reinvigorated. Further, the Independent Race Equality Framework Advisor had previously made a recommendation involving funding the implementation of a low cost community intervention project with the aim of bringing about lifestyle changes that would a) prevent and b) improve management, of these diseases.||
||Population Health Directorate|
||Healthcare Quality & Improvement Directorate|
|4. Fair Work Practices||The joint statement on fair work expectations during the transition out of lockdown and the guidance on workplace risk assessment are welcome. However, studies highlighted earlier in this paper show that discrimination and unfair practices towards minority ethnic people has taken place. The Scottish Government, NHS Scotland and other partners must demonstrate how they will ensure that fair work practices are in place in health and social care settings, particularly in relation to PPE, and other workplaces.||Initial draft of Fair Work race equality statement to be used as a resource for employers and circulated to stakeholders for comment ahead of further drafting and final publication in February 2021.||Remobilisation plans for the NHS now include a focus for Health Boards on understanding and addressing systemic racism, in terms of staff experience, recruitment, retention and progression. This will help ensure that all staff are supported, developed and protected in an equitable way.
In July we published COVID-19 Occupational Risk Assessment Guidance. Staff should be active participants in this risk assessment which uses factors including age, ethnicity, BMI in addition to underlying health conditions to stratify risk. Staff and managers should then have a supportive conversation about how they can return to work safely which should be agreed by both parties.
Launch of the NHS National Ethnic Minority Forum
To deliver on our PfG commitments we have established an NHS National Ethnic Minority Forum (EMF) which had its first meeting on 26 April. There were over 40 attendees including Senior Leaders and staff representatives from local networks. However, going forward the Forum will be largely staff focussed with representatives from NHS Board, professional bodies and partnership organisations’ race equality forums.
The networks objectives are to:
|Fair Work and Health Workforce||Ongoing|
|5. Investment in Minority Ethnic Organisations and Mental Health Services||In the event of enhanced lockdown, the Scottish Government will need to invest in NHS Scotland Mental Health provision.
Further, there should be support for minority ethnic led sector organisations to provide the service required to Scotland’s diverse demographics.
In addition, the Scottish Government and NHS Scotland should deploy culturally competent and multi-lingual psychotherapists and counsellors as there are ethnic inequalities in accessing mental health services. For example, building on the work already done in Scotland by BEMIS, FENIKS, Saheliya, Sikh Sanjog, Amina Muslim Women Resource Centre, YCSA and others and also the internationally recognised community led partnership model involving statutory organisations, private and third sector to support mental health improvement developed by Black Thrive London. More broadly the Scottish Government should commission research to identify barriers and put in place a plan to address the unmet need and persistent ethnic inequalities in mental health care.
The Mental Health Transition and Recovery Plan sets out over 100 actions in response to the pandemic. It is supported by a £120 million fund announced in February. Initial funding has been issued to NHS boards for CAMHS and Psychological Therapies Services. We are in the process of allocating the remainder of the funding which will have a focus on wider support for mental health and wellbeing, including primary care and community services.
Culturally competent services
|Directorate for Mental Health and Social Care||Ongoing|
|6. Public Health Messaging||The Scottish Government must take action to ensure the inclusivity of public health messaging around COVID-19 minority ethnic communities and migrants. This should take into account language barriers, literacy levels, cultural factors, religious beliefs and differential access to health-related information among diverse communities. We endorse the recent SAGE advice:
“An effective communication strategy should target capability (knowledge and skills), opportunity (societal norms and physical resources) and motivation (analytic decision making and habit). Translation is necessary, but not sufficient. Co-production and pre-testing of messaging with communities is essential for tailoring to specific cultural contexts. Local authorities need to have appropriately experienced staff or access to sources of advice so they can actively engage with ethnic communities to understand local issues and act as trusted sources of communication with the community. Messages should be tailored to reflect local realities and consider cultural norms, accessibility of services, and financial disadvantage. Messaging and engagement needs to understand that groups are not homogenous. Work needs done at a local level – it is essential to work with trusted 3rd parties in the relevant communities.” There is concern that public communication around the higher proportion of cases in minority ethnic communities’ could risk creating a blame-game that would lead to negative repercussions for these groups. Anecdotal evidence suggests this has already been happening in Scotland for many groups, including the Chinese community. The Scottish Government should be clear and resolute in standing up to this danger, especially the potential exploitation of this narrative by racists and the far right.
||Covid Public Health Directorate||Ongoing|
|7. Accountability – Independent Oversight Commission||A key recommendation is to establish a more effective accountability and governance infrastructure in Scotland. Too often recommendations have been made on racism and minority ethnic “issues” that have subsequently been forgotten and not implemented. They may then be raised again by other Groups without reference to what has been asked before. This absence of institutional memory within the current system and structures is frustrating, disempowering and can be understood as a mechanism by which systemic discrimination occurs.
The proposal is that a new infrastructure, building on what exists already, should embed four elements
The Oversight Commission should provide strategic oversight to the progression of the recommendations made by the Group and also any future Race Equality Action Plans put in place by the Scottish Government.
The ERG propose that options for the status, structure, remit, staffing complement and resourcing of the Oversight Commission needs to be urgently explored, including with the full co-participation of minority ethnic people and communities. This could be a statutory body in a similar vein to the Scottish Human Rights Commission or an independent body funded by the Scottish Government to complement, enhance and add momentum to the work of the Race Equality Unit, 3rd sector partners, local authorities, and other public bodies The Commission would, through a human rights based approach, ensure that its actions and evidence are informed via the co-participation of minority ethnic people and communities and help establish the infrastructure to house the recommendations which embed the four elements described in paragraph 36 above.
|We aim to publish the REAP final report on 12 March. The delivery of this report will inform plans for a future renewal of the REAP, which will allow for the incorporation of these recommendations fully into our further plans to work towards race equality in Scotland.||Action to meet these recommendations commenced as part of the strategic review (see above). Models of governance and oversight are being reviewed: looking at exemplars in race equality in operation in other countries; as well as selected models established in other policy areas. They will be considered alongside the model of an independent oversight commission to determine an optimal model. As a contributor to this work, we have commissioned the OECD to review approaches to race equality in a selection of countries worldwide.||Equality, Inclusion & Human Rights||Ongoing|
|8. Functions||The functions of the infrastructure should include:
||We aim to publish the REAP final report on 12 March. The delivery of this report will inform plans for a future renewal of the REAP, which will allow for the incorporation of these recommendations fully into our further plans to work towards race equality in Scotland.||See above||Equality, Inclusion & Human Rights|
|9. Anti-Racism Actions||Given the new post-COVID-19 landscape and the highlighting of problems of institutional racism within the existing functions and systems of the state there needs to be a focus on racism and anti-racism actions within the strategies and plans across the Scottish Government, local authorities and public bodies. The Race Equality Action Plan is due to be renewed in 2021 and to ensure that a gap is not created as a result of the Scottish Parliamentary elections next year, planning for the renewal should start as soon as possible, with a clear focus that the actions in any revised plan will be explicitly anti-racist, with clear actions, outputs and measurable outcomes.||We aim to publish the REAP final report on 12 March. The delivery of this report will inform plans for a future renewal of the REAP, which will allow for the incorporation of these recommendations fully into our further plans to work towards race equality in Scotland.||The need for our ongoing work to focus on racism and anti-racism actions is the basis for the twin-track approach we are taking as part of this immediate priorities plan. A large part of the early strategic development work has focused upon the steps that the government has needed to take in order for any change to be substantive, measurable, structural and systemic. The result of this has produced the document of the strategic review of race equality work, informed by the work undertaken by CRER in Spring 2021).||Equality, Inclusion & Human Rights||Ongoing|
|10. Corporate Accountability||An anti-racist progress measure should be included in the performance objectives of all Scottish Government Directors and Chief Executives (or equivalent) of every public body in Scotland. This will help ensure that addressing systemic racism gets the leadership it requires and senior public sector managers will be accountable for actions taken.||Not reported.||Mandatory diversity and inclusion training has also begun roll-out across the Scottish Government to build foundational level of knowledge about inclusion. It includes a specific solution for senior civil servants focused on inclusive leadership in practice, shaping an organisational culture and understanding how systemic manifest operate in an organisation.
In addition to this, we commissioned CRER to identify examples of anti-racist performance objectives with proposed performance measures that could be utilised by Scottish Government and public bodies across Scotland. CRER have been invited to present their findings to People Directorate in October. These objectives and performance measures will be set for NHS Chairs.
|11. National Performance Framework||The National Performance Framework must include analysis and narrative on disparities for minority ethnic people within all progress reporting. Work to improve the data and evidence across Scottish Government must be undertaken and where data disaggregated by ethnicity is not available, there should be the necessary resources to make the investments or policy changes to address this.||January to May 2021
||We take seriously the role of good quality analysis to inform work to tackle racism. Around half (19 of a theoretical 42) of the National Performance Framework outcome indicators are currently reporting an ethnicity breakdown, with work ongoing to add to that number, where data permits.
As this work continues, additional narrative on the equality breakdowns (including ethnicity) for indicators is being added to the website on a rolling basis as indicators are updated. In addition, ongoing research is examining equality data collection in the public sector to improve understanding of current practice and barriers to collection.
The Equality Data Improvement project (EDIP) is led by the equality analysis team. Its project board is chaired by the Chief Social Researcher and Chief Statistician and includes senior policy and analytical colleagues along with external stakeholders. The programme has a component within its project plan to analyse individual or household based NPF indicators to identify the extent to which equality breakdowns are available, and for each indicator set out a plan to either allow analysis of the existing indicator by protected characteristic or to identify an alternative means to provide evidence. We are also in the process of engaging data users of the NPF as part of our ongoing improvement work.
|National Performance Framework||Ongoing The first phase of the EDIP commenced in April 2021, and comprises a series of projects led by the Scottish Government that will be undertaken over a 12 to 18 month period.|
|12. A Measure of Racism||The Scottish Government should explore the development of a workable measure of racism and discrimination and its impact on physical and mental health. This should be done in collaboration with leading international experts and be supported through a programme of rapid learning from the experiences internationally.||Not reported.||This recommendation is being considered as part of the strategic review.||Equality, Inclusion & Human Rights||Ongoing|
|13. Housing and Overcrowding||The Scottish Government must take action with local authorities to mitigate the risk of poor accommodation or overcrowding in some minority ethnic groups, such as migrant workers, asylum seekers and Gypsy Travellers. Housing conditions have been suggested as one of the possible explanations for the disproportionate impact of COVID-19 on BME groups. In particular, the low percentage of minority ethnic people in social housing should be looked at and addressed as set out in a recent report. The report also highlights the various housing and homeless issues facing minority ethnic groups and suggests a number of recommendations, including the need to have reliable and up-to-date data and the need to close evidence gaps and identify solutions.||Not reported.||We published the evidence review on the housing needs and experiences of minority ethnic groups evidence review on 29 January 2021. We also held a cross-Government discussion of the findings on 25 January 2021 to enable a strategic and coherent approach across policy areas. This evidence review informed development of the equality position statement underpinning the Housing to 2040 strategy published by Government in March 2021.
Housing to 2040 restates our commitment to address the housing challenges faced by minority ethnic communities by acting on what we already know, as well as improving our evidence base. In particular we commit to:
Gypsy/Traveller Accommodation Fund As a result of work with COSLA under our shared action plan “Improving the Lives of Gypsy/Travellers”, the Housing to 2040 strategy includes a commitment to make up to £20 million of funding available over five years from 2021/22 for more and better Gypsy/Traveller accommodation. This builds on the £2 million short term funding provided in 2020/21 and represents a sustained investment to support local authorities to provide more and better accommodation for Gypsy/Travellers. Alongside this, to drive improvement in the quality of sites, we are developing a Design Guide for Gypsy/Traveller sites, in conjunction with residents and local authorities.
|Housing and Social Justice||Ongoing|
|14. Recovery and Remobilisation Plans, Investment Fund and Reporting||(a) The Scottish Government should take action to ensure that COVID does not exacerbate existing racialised socio-economic inequalities, including measures to ensure that recovery and remobilisation plans do not discriminate against people from ethnic minorities.||Not reported.||Recovery and Remobilisation
The ALLIANCE was commissioned to undertake community engagement work, titled ‘People at the Centre’ to ensure that the diverse experience and broad range of perspectives from patients and carers are fed into the work of the MRG and its members. A final report summarising the overall findings was published by The ALLIANCE on 18 February 2021. The research worked with people from minority ethnic backgrounds & communities and different faith groups and found that health inequalities have been exacerbated and population groups disproportionately impacted. Key issues raised include the compounding of structural barriers by a lack of communications in people’s preferred language, the stigmatisation often encountered when accessing healthcare services, and the importance of cultural and religious sensitivity.
|Health Inequalities Unit, Territorial Board Planning & Performance||Ongoing|
|(b) The Scottish Government’s response to the Advisory Group on Economic Recovery recognised the necessity of embedding an Equalities and Human Rights approach across our policy thinking and development for economic recovery and renewal. The response recognised in the need for action in areas such as employment, skills and training, job support for young people and support for those seeking work or at risk of long-term unemployment. Opportunities for minority ethnic youth must be targeted and progressed as part of contractual agreements where public bodies are spending on significant capital infrastructure projects or modern apprenticeship programmes.||Not reported||Young Person’s Guarantee
The Youth Guarantee - No-One Left Behind: Initial Report was published in September 2020.
An Implementation Group made up of partners from the public sector, third sector, and private sector co-produced and published an Activity Plan setting out the initial high-level activities required to implement the Guarantee. The Scottish Government has provided funding to create around 18,000 opportunities for young people from the £60 million committed to support implementation of the Guarantee in 2020/21. A further £70 million has been committed for 2021/22.
|( c )The Scottish Government should take action to set up a Race Equality Transformational Investment Scheme. This fund should focus on the systemic change issues highlighted in this paper and use a participatory and empowerment model where ethnic minority communities are able to direct funding to areas of public service that need to change during the upcoming recovery and remobilisation phases.||Not reported||Race Equality Transformational Investment Scheme Officials from across government have come together to scope the possibility of a transformational investment scheme. Work is underway to review viable funding mechanisms including determining the scope of the Shared Prosperity Fund, the replacement for the European Structural Fund, as a potential avenue. Additional funding made available through our Youth Guarantee and No One Left Behind initiatives for 2021/22 has contributed to our recovery and remobilisation response around employment, skills and training||Equality, Inclusion & Human Rights||Ongoing|
|15. Employment||All public bodies should develop action plans with annual progressive targets for public sector employment at all levels of seniority in relation to minority ethnic groups – workplaces must reflect the diversity of the communities they serve and also set a positive leadership example. These targets should support achievement of the existing commitment on fair representation for minority ethnic people in the Scottish Government and public bodies workforce. Appropriate levers to encourage similar actions from the private sector should also explored, including the potential to support community and activist led programmes, such as "Pull Up or Shut Up,” a campaign that calls on companies to release the total number of black employees at their companies and to identify their employment levels.||
||A group of public sector employers meet once a month to discuss the implementation of this recommendation. Meetings allow for knowledge and practice exchange and reflect key themes within the Minority Ethnic Recruitment Toolkit. The group is currently preparing run an engagement session with minority ethnic community stakeholders and jobseekers in late September to This is to highlight the benefits of working in the public sector and to identify and address employment barriers for ME job seekers in these organisations. Longer term, the group will discuss and agree an action plan to ensure continuous learning and improvement.
We are also continuing to engage with employers on recruitment practice as part of the work following the Public Sector Leadership Summit on Race Equality in Employment. This follows the inquiry by the Equality and Human Rights Committee inquiry report into the pertinent issues preventing positive outcomes for minority ethnic people in Scotland moving into, staying in and progressing in employment. It brought together Ministers, public authority leaders and key stakeholders to support public authorities and seek from them an understanding of institutional racism and the structural barriers that may exist in their organisations, and a commitment to take forward the Committee’s recommendations.
The summit unveiled a joint commitment which pledges Scottish Government and public sector leaders to: take forward the Committee’s recommendations, embed them in the strategic objectives of their organisation and in their performance objectives, and to make the commitment public-facing by publishing it on their websites and social media channels.
The summit will be followed by workshops led by public authorities and framed around the Committee’s recommendations pertaining to recruitment and retention practices, including use of the Minority Ethnic Recruitment Toolkit; and the gathering and application of ethnicity workforce data. These workshops will take place in the coming months and will conclude by the end of the year.
We will also look to engage with employers on recruitment, retention and progression practices as part of the development of our ethnicity pay gap strategy., The new Government commitment to develop an ethnicity pay gap strategy will support public authorities to:
Fair Work First guidance was published in January this year. This guidance outlines our Fair Work First approach and exemplifies the Fair Work First criteria in practice. Officials are working to develop a monitoring and measurement framework to gather information about the change and impact for individuals and organisations.
In the summer we will launch a consultation on our vision to be a Fair Work nation by 2025, which will cover questions on improving workplace equality, including race equality. We have drafted the Fair Work race equality statement and resource for employers , which is out for circulation to policy leads where there is read-across. It will shortly go out to external stakeholders, including employers, trade unions and race equality stakeholders for comment. Publication will likely be in the autumn this year allowing for further drafting and to ensure a full review following contributions.
|Changing the Cultural Landscape|
|16. Change the Curriculum for Excellence||The Scottish Government should make a formal change to the school curriculum as advocated by CRER and BEMIS. The Government should amend the Curriculum for Excellence Social Studies benchmarks to include a specific experiences and outcomes measure such as:
‘I understand Scotland’s historical role in empire, colonialism and transatlantic slavery and how that history has manifest the present and also understand the diversity of Scottish society in the past.’ There should also be the potential within the curriculum for a much wider understanding of global Black history
A summary document will be published containing identified actionsApril 2021
|As of July 2021, the Race Equality and Anti-Racism in Education Programme (REAREP) Stakeholder Network Group had met 5 times (monthly). The Stakeholder Network Group consists of key education and race equality organisations and individuals. Four of those meetings focused on the four key themes which stakeholders agreed were interlinked and of fundamental importance in order to tackle race inequality and embed anti-racism in schools:
It met for the first time in August, co-chaired by Khadija Mohammed from University West of Scotland and Jovan Rao Ryder from Intercultural Youth Scotland and involves education practitioners, the anti-racist education sector, young people and local and central government bodies. Consideration of curriculum framework change will be one of the key roles of the SubGroup.
The Group’s draft vision is as follows:
Scotland’s schools and early learning environments will promote and embed racial equity, anti-racism and global citizenship through its systems, leadership and curriculum. All of our learners, communities and practitioners will benefit from a curriculum, culture and ethos that reflects the diversity of the school community, Scotland and the wider world. The role of Scotland and the UK in colonial history and the impact it has on the modern world will feature in teaching and learning to ensure our young people have an understanding and awareness of the British Empire and colonialism, including slavery and other human rights violations, past and present.
|Equality in Education|
|17. National Museums and Statues||The Scottish Government should work with the existing group co-chaired by CRER and Glasgow City Council and community members to fund a scoping study for the establishment of a national museum dedicated to illuminating Scotland’s role in empire, colonialism, slavery, migration and the history of Scotland’s erasure of that history. Ethnic minority people, in particular people from African and Caribbean communities, must be over represented within any such work. Further, statues have become a focus in the global moment and clarified for all that they mean, what obfuscated reality they reflect, and asks the question of what they are saying and to whom? The Scottish Government should be bold, creative and proactive, and include young and older Afro Caribbean and people of African descent in Scotland in any decision making on any future decisions on statues and other cultural artefacts.||
||Since December 2020, we have continued to work with the Steering Group established focusing on Empire, Slavery and Scotland’s Museums (ESSM). ESSM has continued to action plans and processes around its original membership and remit. The call for research is complete and the group has analysed the sector wide findings. Several distinct strands of work were identified as a result and thematic sub-groups were set-up to examine each more closely. The last sub-group meetings were held in June 2021, and although the project has a revised timeline with a six month extension, good progress has been made.
Unforeseen challenges around identifying external contractors who felt they lacked the necessary understanding of diversity and the access to the priority communities necessary to deliver the consultation(s) has resulted in a delay – with the national consultation now planned to begin in August 2021. We expect the final recommendations of the group to be delivered in April/May 2022.
|Equality, Inclusion & Human Rights|
|Improving Data and Evidence on Ethnic Inequalities in Health Improving ethnicity coding through improved data infrastructure|
|1. Make Ethnicity a Mandatory Field for Health Databases||This is an immediate action that should be done for one or more systems E.g. primary care databases, Scottish Morbidity Records and others. We recognise that making a field mandatory at the national level is not necessarily a panacea but in our view it is essential to improving the data in the short and longer terms. It means a valid code has to be submitted for each record in Board data submissions. ‘Refused’ and ‘Unknown’ are valid codes so even if then it does not mean it is available for all patients. At present, data held by PHS does not discriminate between these two concepts and only includes a single code for ‘refused’/’unknown’, likely including many instances when the patient was never asked. Further work is needed to understand if it is possible to create more refined categories for unknown ethnicity, requiring an improved understanding of the source data within health boards and whether the current computer systems used by health boards allow for more detailed information to be collated. In addition, mandatory does not mean accurate, any code will be accepted, and so data needs to be good quality and this needs data quality monitoring at local and national levels. Given the ownership of much data collection lies with NHS Boards, they should make it mandatory on local systems as well but this would need to go hand in hand with leadership and training initiatives described in the Lothian study and others as described above to ensure quality.||
||Health Data, PHS||Complete|
|2. Linkage to Census||The census currently provides the most robust information on ethnicity for the population of Scotland. Data linkage to the census should be immediately pursued by the Scottish Government to monitor the equity of the COVID-19 response in relation to ethnicity. This should not only include the immediate infectious consequences of COVID-19 (such as risks of infection, hospitalisation and death), but also secondary health harms arising from the pandemic response (such as reductions in the use of appropriate healthcare for other health conditions). If a vaccination becomes available, monitoring of its uptake by ethnicity should also be pursued using data linkage. Under the principle of collecting data once but making use of it many times, linkage to the census should be pursued to allow long-term monitoring and research of ethnic inequalities in health. At present, linkage is done for the purposes of a specific project and for this reason such analyses are often not conducted in a timely manner and are resource intensive. The ERG recommends the addition of an ethnicity field derived from the census is added to an appropriate population spine (such as the Community Health Index, CHI) which would be available for routine analyses without requiring approval from multiple organisations. This recommendation should be considered an important priority which could substantially improve data quality and facilitate timely and responsive analysis.||NRS will continue to review the mortality data to see whether there is added value in updating the analysis a third time. NRS will continue to support researchers through the provision of the Census 2011 data into the National Safe Haven.||The National Records of Scotland (NRS) published analyses of COVID-19-related mortality and ethnicity in 2020, and enabled Census 2011 to be accessible to accredited researchers in the National Safe Haven. We previously highlighted two research projects which are looking at socioeconomic, household and environmental risk factors, and the epidemiology of COVID-19. The necessary governance steps have been completed for these projects and data has been made available to researchers. Census data can only be used for research and statistics projects. Ordinarily, it cannot be used for operational or clinical purposes.
Data linkage to the census data to monitor the equity of Covid-19 can be done on a one off basis right now as it meets the requirement of being a research project. This can be done through the Data and Intelligence Network (D&IN) challenge or the Covid-19 research database. Multiple research questions can be submitted as part of one study, so information on secondary health harms could also be explored alongside the equity of Covid-19 response information. This can be achieved now through the Covid-19 research database.
|Digital Health & Care||Ongoing|
|3. Develop a CHI Field||Allow information to be accessible if provided to any health database only once. This will need maintenance/integration within the Community Health Index (CHI) system and a way for deciding on conflicts in classification between databases and over time. Similarly, some process for updating the information on an occasional basis will likely be necessary. The CHI is due to be substantially revised within the next 1-2 years, providing an opportunity to embed ethnicity within the system. This single change could make a major impact on the potential 7 for conducting analyses of health data by ethnicity, since this information would then be readily available within many health datasets. There would be considerable synergies if combined with recommendation 2.||
||Primary Care, Health Data||Ongoing|
|4. Ethnic Group Populations||Monitoring of health outcomes by ethnic group should be updated regularly and more frequently than the decennial census as it is difficult to monitor without up to date populations on which to base rates. This is particularly the case in Scotland with the relatively small numbers of many minority ethnic groups and also the fact that many minority ethnic groups have relatively young populations compared to White Scottish/British and so risks can be masked by generally better outcomes in younger people if looking at outcomes at an aggregate level (Note, this was case with recent PHS Ethnicity analysis where the raised risk in South Asians was only apparent after adjustment for underlying age and sex in general population). Attempts have been made previously by NRS and ONS to look at inter census estimates but appear to have stalled. A group at Leeds University have produced broad population projections for ethnic groups based on a number of assumptions (ETHPOP12). Similar work to produce inter census estimates should be taken forward by the Scottish Government and the NRS within the next six months.||Not reported.||In order to take action on this recommendation, we have identified research that may be helpful in this kind of data monitoring. The Data & Intelligence Network are working with partners in Research Data Scotland and NRS to create as complete a picture as possible of equality protected characteristics as possible, which will then be available for research and statistical analysis. The EAVE II project as well as this D&IN project aims to bring together an ongoing research database for these kind of questions outside of a COVID lens We are also working to improve Equality Data across the government through the Equality Data Improvement Programme (EDIP) designed to improve and strengthen data on the protected equality characteristics collected and utilised across the public sector. The first phase of this programme comprises a series of projects led by the Scottish Government that will be undertaken over an 18 month period.||Directorate for Digital Health and Care|
|5. Social Care Data||At present, the provision of social care is highly varied across local authorities and data is not collected in a harmonised manner to facilitate robust analysis. There are considerable efforts to improve the quality and harmonisation of data ongoing and the inclusion of ethnicity within such efforts is important. The need for social care provision that is tailored to an ethnically diverse population is likely to increase substantially in coming years, as the proportion of older people who are minority ethnic increases. The Scottish Government and local authorities must make a clear commitment to address data deficits on ethnicity within the social care system.||Not reported.||
||DG Health & Social Care||Ongoing|
|6. Flexibility in Data Collection||The analysis of administrative data provides a number of advantages for monitoring ethnic inequalities, including the large size of datasets (which allows minority ethnic groups to be analysed) and its relative efficiency and affordability. However, administrative data will not always be appropriate and there will continue to be a need for bespoke data collection for specific purposes, including monitoring the needs of particularly vulnerable groups or when administrative data does not capture the required information. For example, migrants who have no recourse to public funds are a particularly vulnerable group and specific data collection efforts may be required to respond to their needs. Sufficient resources will need to be made available for data collection for these specific purposes. Furthermore, existing survey datasets often do not include large enough groups of minority ethnic people to allow analyses by ethnicity. Consideration should be given to the need for boosting samples of ethnic minority participants. Often there will be a strong case for collecting qualitative data to supplement the quantitative data that has been the focus of this paper.||
||DG Health & Social Care||Ongoing|
|Improving ethnicity data collection at source|
|7. Co-ordinated Action||A co-ordinated set of initiatives must be put in place by the Scottish Government and NHS Scotland as soon as possible building on the lessons from past successes to improve recording of ethnicity within health databases. The COVID-19 pandemic provides a clear illustration of the importance of collecting this data, so such action has a greater chance of success than in the past. These initiatives cannot be one-off projects but rather a sustained plan of action that embeds the process of ethnicity data collection in the culture of the NHS in Scotland.||Not reported.||
||DG Health & Social Care||Ongoing|
|8. Primary Care Health Ethnicity Data Collection||Collection of ethnicity information at the time of GP registration provides an opportunity for substantial improvements to health ethnicity data. The current level of completeness is low, so mandating ethnicity data collection within general practice must be taken forward by the Scottish Government. However, the pressures on general practice are considerable at this time, so there is a need to ensure partnership with GPs, the Royal College of General Practitioners and other primary care staff to explore how best to take this work forward.||
||Public Health Scotland, Primary Care Directorate||Ongoing|
|9. Participation by Minority Ethnic People and Communities||Minority ethnic people and communities must be at the heart of any initiatives to improve ethnicity recording and closely involved in driving forward such initiatives. Minority ethnic communities racialised by the data process need to be involved to make sure it is worthwhile and not just another tick box exercise. This will help ensure the work meets the needs of Scotland’s diverse communities and also facilitate success. It should be noted that not being willing to provide ethnicity information is rare when the reason for its collection is appropriately explained. The perspectives of minority ethnic people and communities should also be brought into the data collection process to ensure greater understanding in relation to the importance of safeguarding data. Caldicott guardians should be supported to understand how racism and racialisation plays out in the systems of data collection and analysis in order to inform their responsibilities regarding the lawful and ethical processing of information. This should include awareness of the risks of both use and non-use of data.||Not reported.||This cuts across all the recommendations, including systemic issues. Implementing this recommendation means ongoing engagement with key partners in ERG, BEMIS, and CRER for example, as well as involvement of individuals representing communities participating in workshops and SLWGs set up to address specific recommendations.
Discussions have begun with BEMIS and CRER as to how this can be taken forward as part of the IPP. ERG co-chairs’ advice has been sought for representation at workshops and SLWGs
Within Health & Social Care, work to improve understanding of concerns and constraints of particular Minority Ethnic communities regarding vaccination update included:
|DG HSC, Equality, Inclusion & Human Rights, Public Health Directorate||Ongoing|
|Improving Workforce Data|
|10. Monitoring Workforce Data||COVID-19 has highlighted the issue of racism experienced by many of those working in the health and social care sector. While overt racism is relatively uncommon, evidence of institutional discrimination has accumulated. For example, minority ethnic groups have been more likely to report inadequate or needing to re-use personal and protective equipment. More generally and before the COVID-19 pandemic, a special series within the BMJ medical journal highlighted the systemic nature of racism within Medicine, with minority ethnic groups less likely to be promoted and occupy positions of prestige.
Monitoring of the minority ethnic diversity of frontline NHS and social care staff is required urgently by NHS Scotland to be able to appropriately respond to concerns raised by employee representative bodies such as the Unison and STUC Black workers committees. In respect of COVID-19, unions identified that Black workers were disproportionately exposed to COVID risks. The experience of Black workers and others highlights both the legal duty to respond to these minority ethnic workers and also instigate transformative consultations with workers and others to respond to the experience of racialisation in our institutions and systems. NHS Scotland and public service organisations should put in place effective and sustained systems to record ethnicity of the workforce and analyse workforce data and surveys to show the variation in experience of employment by ethnic group.
||Public Health Scotland (social care data) Health Workforce (NHS workforce data)||Ongoing The timescale is likely to be no less than two years based on the experience of England in its implementation of a system that would correspond to the recommendation|
|11. NHS Workforce Data||NHS Education for Scotland (NES) are responsible for collecting, analysing and publishing NHS workforce data and high level ethnicity data is published annually. NES must address data quality issues and regularly report on progress in achieving equity in relation to NHS workforce issues for minority ethnic staff. This includes information on pay, promotion and recruitment. We would expect NES to monitor the quality and completeness of the data and report regularly on any gaps within that data. We would also expect the Scottish Government to provide oversight of progress on improvement.||Not reported.||
|12. Social Care Workforce Data||At present, no national workforce data for social care is available for Scotland, with individual local authorities responsible for its provision. Data does not appear to be regularly collated or reported and this may mean that monitoring by ethnicity is not possible within much of Scotland due to the relatively small numbers of minority ethnic people in many individual local authorities. Given the integration of health and social care, joint work by Scottish Government and local authorities is needed to ensure that minority ethnic workers are treated equitably within social care. This may require data specifications to be included within contracting processes made between commissioners and providers, informed by nationally agreed data standards. This would allow minority ethnic groups to be studied at a national level.||Not reported.||
||Health Workforce||Ongoing The timescale is likely to be no less than two years based on the experience of England in its implementation of a system that would correspond to the recommendation|
|Reporting, Accountability and Governance|
|13. Reporting Data by Ethnicity||The COVID-19 pandemic has highlighted the need for ongoing monitoring of health (and other) data by ethnicity. The lack of reporting of datasets that are available by ethnicity can serve to make ethnic inequalities in health hidden and threatens the case for maintaining data quality. It is therefore crucial that data when available and robust enough for analysis are published and disseminated to policymakers, practitioners and communities. We recommend that:
||Not reported.||Work is ongoing to link impact data from COVID-19 to the National Performance Framework.||Equalities data analytics||Ongoing|
|Public Health Scotland must publish an annual monitoring report on ethnic group health inequalities in Scotland.||Not reported.||
||Public Health Scotland|
|The National Performance Framework must include specific indicators on the impact of racialised inequalities or the impact of systemic racism on minority ethnic people to supplement the current 81 National Indicators.||National Performance Framework
There is a statutory requirement for the NPF to be reviewed within every five years, with the next review due to commence by May 2023 at the latest. [NOTE: this could commence sooner, subject to decision by Ministers]
Options and timing for the NPF review are currently being considered and it will need to align within the Government’s priorities e.g. on Covid recovery, and the legislative programme.
The review provides the opportunity to examine improvements to the NPF including how it will need to adapt in response to the issues highlighted by the COVID-19 pandemic and subsequent developments. While staff resources are constrained, NPF team have made a bid for an SGSSS PhD intern to start a programme of work to review equality information (including ethnicity) reported within the NPF and make recommendations on how to improve NPF reporting in this area going forward.
|14. Accountability and Governance||In order to ensure that issues on racism and ethnicity are taken seriously then people within Scottish Government, the NHS, local authorities and other public sector organisations need to be accountable for taking forward this advice and recommendations with speed and commitment. Putting a measurable racism and ethnicity objective in every Scottish Government Health Director and NHS Chief Executive’s performance objectives would provide some motivation and personal incentive to drive this forward. The ERG would be happy to discuss what these objectives could be.||Not reported.||Racism and ethnicity objectives
||Health Workforce Directorate||Ongoing|
|Each public body that has duties under the Equality Act should publish its scheme of governance to ensure adequate data recording, analysis and presentation of information to demonstrate their commitment to monitoring and tackling inequalities. Public bodies should do this in the interests of access, experience and outcome for services to minority ethnic groups that it provides, providing specific analysis of conditions of interest such as COVID-19, and the fair employment of staff by ethnic group using agreed indicators. In line with the reporting recommendation in relation to the National Performance Framework above, actions taken to improve indicators contained within the National Performance Framework should be publicly reported, with designated Scottish Government leads for responding to each indicator.||Public bodies
Although the 2010 Act is largely reserved, Scottish Ministers have supplemented the general duty by placing detailed requirements on Scottish public authorities through the Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012 (as amended). These Regulations apply to listed authorities with twenty or more employees and include two elements for reporting on staff (including in regard to ethnicity).
The first element is a general duty on each listed public authority to annually gather and use information on the composition of its employees, as well as on their recruitment, development and retention, all broken down by relevant protected characteristic. This information is published every second year.
In addition, every four years, public authorities must publish a policy on equal pay among its employees, including between staff who fall into a minority racial group and those who do not. At the same time authorities must publish information on occupational segregation among its employees, including the concentration in particular grades and particular occupations of staff who fall into a minority racial group and staff who do not.
The Scottish Government published its own ethnicity pay gap figure as part of its 2021 Equality Outcomes Mainstreaming Report
The SNP manifesto contained a commitment to extension of pay gap reporting, therefore we will expand the duties within the Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012 that require a listed public authority to publish gender pay gap information to disability and ethnicity reporting and ensure these are included within Equal Pay Statements.
The Scottish Government is progressing a review of the operation of the PSED in Scotland and published in March 2021 a stage one report which set out learning from the experience of seeking to discharge the equality duty during the COVID-19 pandemic. Stage two of the review will include further stakeholder engagement and consultation with a view to progressing the areas of focus identified in the stage one report in order to improve the operation of the PSED in Scotland. This further engagement will ensure that we can learn from practice and compliance with the existing regulations on data and reporting and will help to inform how we can apply the proposed new duties on ethnicity and disability pay gap reporting.
Policy/Analytical leads for each NPF indicator already exist within the Scottish Government, with the National Performance Framework Unit acting to facilitate communication with indicator leads on enquiries into NPF indicators.
The Equality Data Improvement project (EDIP) is led by the equality analysis team. It is supported by a project board established by the Scottish Government and chaired by the Chief Social Researcher and Chief Statistician,
A page outlining changes and updates to the indicators within the National Performance Framework has been added to the NPF website, and will be reporting on changes to NPF indicators going forward.
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