Race equality: immediate priorities plan

Progress made on the actions taken to implement the recommendations of the Expert Reference Group for COVID-19 and Ethnicity, and continuing work on race equality across government.

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.
  • Pathways Programme to submit a proposal to the Test & Protect (T&P) Steering Group for the establishment of a dedicated Customer Insights Function, by the end of December 2020. If approved, the new Function will be operational before May 2021.
  • Complete a qualitative study to gain feedback from users by the end of May 2021.
  • Partnership working with the Health and Social Care Alliance citizen panel to be established by May 2021.
  • Feedback loops to be developed from existing channels/sources e.g. Care Opinion and Health Board complaints data.
  • Planning to establish ad hoc insight sources to support design-led improvement.
  • All new Pathways that are commissioned by the Design Authority will be developed through the T&P Equality Impact Assessment lens.
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:
  • An equality and inclusion representative on the Test & Protect Design Authority.
  • Established the T&P Insights Group.
  • Reviewed guidance to ensure communities most at risk have access to testing.
  • Translated key documents into 7 languages, as requested by our local partners.
  • Developed a self-isolation factsheet and translated it into 26 languages
  • Translated messaging about the Self-Isolation Support Grant. This has been well-received by community groups.
  • Engaged with the Ethnic Minority National Resilience Network to identify where improvements can be made.
  • Public Health Scotland worked with the Contact Tracing programme to implement improvements, such as the use of SMS messages in other languages, moving the recording of preferred language to earlier on in the testing and protect process, improving the continuous professional development of contact tracers with respect to the importance of collecting ethnicity data to monitor engagement with the service.
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:
  • Having a fortnightly National Inclusive Steering Group with membership representing minority ethnic communities.
  • Asking Health Board to incorporate specific actions to reach minority ethnic communities into their inclusive plans developed in spring.
  • Funding and targeted engagement with third and community sector organisations to support and promote vaccine uptake amongst ME communities.
  • Co-creating vaccination information materials with organisations such as the Scottish Refugee Council, translating them into a range of community languages, and including a QR code on each appointment invite to ensure people are able to quickly access the information in their own language.
Vaccination Strategy & Policy Directorate
  • In December, information for highest risk people concerning festive bubbles along with a user survey was issued.
  • In January 2021, an EQIA of the QCovid Risk model will be conducted to determine the equalities impact. Vaccine information will also be mailed out.
To ensure the needs of Minority Ethnic communities on the highest risk list (formerly shielding) are considered, we:
  • Established a number of communications channels specifically for minority ethnic people who are at highest risk.
  • Write to all new additions within a week of them being added. Letters are available to be translated into any format and language needed.
  • Are working with The University of Edinburgh, PHS, NES Digital and NHS Digital in England on the exploration of the QCovid model developed by Oxford University. QCovid uses a range of data including age, sex, ethnicity and existing medical conditions, to estimate the risk of death or hospitalisation from COVID-19 and then presents a risk calculation.
  • Carried out an Equality Impact Assessment (EQIA) on the QCovid Model, following internal framing workshops with the Scottish Government’s Equality & Mainstreaming colleagues, and engaged with key stakeholders which helped shape and contribute to the EQIA.
  • Presented a data paper on 22 June 2021 which received support from the COVID Ready Society Group. We are continuing to explore how we can collate better ethnicity data.
  • Continue to engage with people on the highest risk list to ensure their needs are met, actively ensuring respondents in our research represent people from Minority Ethnic communities.
  • Requested Minority Ethnic individuals to join our user insight group, and collected equality data. Our ‘research participant list’, increased in this period from 3,758 people to 6,429.
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.
  • The first report on Referrals to NHS board commissioned weight management services, containing data on ethnicity, was published by Public Health Scotland in May 2021.
  • A refresh of the Diabetes Improvement Plan was published in February 2021. Equality of Access to reduce the impact of deprivation, ethnicity and disadvantage on diabetes care and outcomes is one of the priorities for improvement.
  • We have allocated funding to three Health Boards to implement the digital type 2 diabetes prevention and education programmes provided by Oviva. These programmes are delivered by dietitians and offered in 22 different languages to meet the needs of minority ethnic groups who are at higher risk of developing type 2 diabetes.
Population Health Directorate
  • We aim to have a final draft of the plan, and an established governance structure for its delivery by May 2021.
  • The Heart Disease Action Plan (HDAP) was published in March 2021.
  • To deliver actions from the plan, a Risk Factor Sub Group of the National Heart Disease Task Force is to be established.
  • The ALLIANCE has been commissioned to support a robust lived experience structure to feed into the implementation of the HDAP, with a particular focus on inclusion of the South Asian community within that structure, due to disproportionately high risk of cardiovascular disease among this community.
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:
  • Ensure recruitment practices for Sr appointments are fair and unbiased
  • establish a formal structure connects these networks in order to provide an effective, agile channel for workforce engagement.
  • link with other equality networks
  • identify and introduce senior cross-sector mentoring and job shadowing opportunities for ethnic minority staff
  • introduce a cross sector mental health support network providing practical advice and signposting ethnic minority members towards appropriate clinical support.
  • produce a simple guide for organisations enable more confident and mature discussions to take place about race and race equality.
The next meeting was held on 12 July, where we confirmed forum membership and chair and vice chair so that work can begin being taken forward. We finalised a draft of the Fair Work race equality statement and resource , which we are circulating to internal stakeholders for comment, including policy leads where there is read across. Publication date has been postponed to ensure full review can be undertaken. We will also shortly circulate the statement to our external stakeholders, including race equality stakeholders, employers and Trade Unions. We will then amend/refine further ahead of publication inthe autumn.. Once published we will explore how employers can make best use of it and embed it within existing resources to support employers.
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.
  • By February 2021, we will have convened an expert equalities forum who will have commenced work to ensure an overall focus on reducing mental health inequalities.

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
  • A Mental Health Equality and Human Rights Forum has been set up. It includes BEMIS as representation on race equality amongst other key stakeholders representing diverse communities in Scotland.
  • The group advises on the implementation and delivery of Mental Health Policy and actions within the Transition and Recovery Plan.
  • We are looking at ways to improve our engagement with people who have lived experience of mental health services.
  • We have worked with public and third sector partners to understand language and accessibility requirements and to create and disseminate information.
  • We provided Summary Guidance of the Clear Your Head campaign in additional languages and formats, distributed these to Public and Third Sector Equality partners such as BEMIS, MECOPP (Minority Ethic Carers of People Project) and NHS Health Board Equality Leads. These can be found on the Stakeholder Page of the Clear Your Head website.
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.
  • In January and February 2021, the Scottish Government will be undertaking national door drops in support of the coronavirus vaccine, use of NHS services and changes to the organ donation system. These documents will be translated into various languages and formats.
  • Scottish Government will continue to involve a diverse range of individuals in focus groups for creative testing.
  • Our “Roll Up Your Sleeves” COVID-19 vaccine campaign has budget allocation for media channels that support targeting Minority Ethnic communities.
  • We work closely with NHS 24, Public Health Scotland and third sector partners to ensure key public health information on COVID-19 is available in multiple languages and accessible formats via the NHS Inform website, which is Scotland’s central repository for public health information. Key COVID content is available in 17 different languages and formats.
  • COVID-19 and Self-Isolation guidance is available in multiple languages and formats and is available on gov.scot. We have worked closely with stakeholders to share this guidance with Minority Ethnic communities, and many of our stakeholders have featured this information as part of their communications.
  • NHS Inform COVID helpline provides interpreter services to support conversations with people whose first language is not English. NHS Inform utilises metadata associated with all alternative language formats, which aids searching for content in these languages.
  • We collaborate with ME partners and stakeholders across our COVID-19 activities. For example, we work closely with BEMIS, the national umbrella body supporting the development of the Ethnic Minorities Voluntary Sector in Scotland, on coronavirus-related public health messaging and information for parents and carers. This includes development of supporting materials and sharing of information across their main networks and membership in Scotland.
  • We co-created coronavirus information with organisations to develop materials specific to Minority Ethnic communities. For example, we worked Scottish Public Health Network (ScotPHN) to create a bespoke, printed Easy Read Version of the Test and Protect Door Drop created specifically for the Gypsy/Traveller community, which was distributed by COSLA to Gypsy/Traveller sites.
  • In partnership with BEMIS and the Ethnic Minority National Resilience Network (EMNRN) we have gathered feedback from Minority Ethnic organisations to shape inclusive communications, which has influenced messaging and available formats. For example, we have used the insight to create a ‘Vaccine Explainer Video’ which provides key facts about the COVID vaccines for those who may be hesitant, or for those more likely to have been exposed to myths/misinformation. This video has also been produced in British Sign Language (BSL) and in multiple community languages.
Covid Public Health Directorate Ongoing
Short-term actions
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
  • An Observatory which brings together quantitative and qualitative data on ethnic and racial inequalities in Scotland. This should not only include epidemiological data but also cultural, historical and other socio political and economic factors.
  • A repository which holds historical and current evidence from arrange of different sources to maintain awareness and inform actions.
  • Collaboration that reflects the consensus between the Scottish Government and all other relevant stakeholders that Scotland needs to better engage with the experiences of those racialised in society.
  • Co-production processes led by those who are most affected by its outcomes.
It is important that there is independent external oversight of the work and linked to work that is being taken forward elsewhere in Scotland. An independent Oversight Commission must be put in place consisting of representatives from minority ethnic communities, academia, third sector and other national and international experts.

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:
  • Collect, analyse and publish government, local authority, public body ethnic, and private sector ethnic minority data and evidence
  • Help Directorates within Scottish Government to develop, monitor, implement and evaluate policies to reduce ethnic disparities
  • Provide leadership to improve the quality of Scottish Government, local authority and other public bodies in their collection, analysis and reporting of data on minority ethnic groups, as well as actions to address these inequalities
  • Report regularly on the impact of policies on racialised inequality in Scotland
  • Create an open data source which is kept updated in order to monitor and act on the impact of Scottish Government plans and expenditure on minority ethnic people and communities.
  • Highlight priority areas for investment to boost progress in affected communities across Scotland.
  • Report and share best practice
As a priority the Scottish Government should conduct an inequalities audit across the Scottish Government and other public bodies functions.
  • Government should work with the NHS, local authorities and other public service partners to ensure that data relating to workforce and the use of public services is accurate, comprehensive, accessible, can be ethnically disaggregated and is regularly monitored and reviewed.
  • That work should include the investigation of any ethnic disparities. Where data disaggregated by ethnicity is not available, the Scottish Government must make the necessary investments or policy changes to address this.
  • Any Scottish infrastructure should be multi-disciplinary, seek international guidance and expertise especially in relation to understanding how systemic, structural/ institutional racism manifests and is sustained, as well as learn lessons from the experiences of the UK Racial Disparities Unit.
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.
People Development Ongoing
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
  • Narrative on equality characteristics (including ethnicity) will be added to appropriate indicators as and when they are updated with new data.
February 2021
  • Conclusion of research examining equality data collection in the public sector to improve our understanding of current practices and barriers to collection.
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:
  • Ensuring that minority ethnic voices are heard in our work to develop a new Rented Sector Strategy
  • The Affordable Housing Supply Programme continues to support the needs of minority ethnic communities, including larger homes where those are needed, where local authorities identify these through their Local Housing Strategies and SHIPs.
  • Including specific consideration of the needs of this group in our review of the adaptations system
  • Taking forward further research work with people from minority ethnic groups to understand and address the barriers they face to accessing social housing.
  • Carrying out a review of the evidence of minority ethnic people’s representation in employment in the housing sector in 2021 and supporting the sector in taking forward any resulting actions.
The Scottish Social Housing Charter is to be reviewed by Scottish Ministers every 5 years. A revised Charter needs to be approved by Parliament by April 2022. We have launched a formal consultation of the Charter on 17th June. This will run until 9th September. We have also commissioned a targeted “involving all” consultation with harder to reach groups; across the range of protected characteristics, including minority ethnic tenants. We are hosting a series of virtual consultation events involving tenants, tenant and resident groups, landlord staff, Councillors, RSL Board members and other interested stakeholders from the 21st June to 15th July 2021 The Housing (Scotland) Act 2014 enables local authorities where there are exceptional cases of poor conditions in the private rented sector, to apply to the Scottish Government for further powers by having an area designated as an Enhanced Enforcement Area (EEA). Glasgow City Council subsequently applied and was granted two EEA designations in Govanhill in Glasgow. The first of these designations ended in September 2020 and a final report to Scottish Ministers from Glasgow City Council about how the powers have been used and the impact this has had is due by mid-July 2021. This report will help feed into our review of registration and regulation systems.

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
  • Scottish Government has created a new Unit that will specifically focus on Health Inequalities. This includes the Fair Health Team which has an ongoing focus on socio-economic drivers of health inequalities and a Health Equalities Team expected to be fully staffed by the end of the year.
  • The Health Inequalities Unit will work closely with Territorial Board Planning & Performance teams to develop a more strategic approach to identifying national priorities on equality, with a particular focus on addressing ethnic health inequalities, and embedding these the work of Government and Health Boards.
  • Improving connections between planning, delivery, and reporting to better support the promotion of equality priorities and delivery of equality outcomes now features as part of the Territorial Board Planning and Performance divisional work plan.
Mobilisation Recovery Group (MRG) work

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.
Fair Work Ongoing
( 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.
  • Adoption of the Minority Ethnic Recruitment Toolkit and its practical guidance in employers’ recruitment processes by May 2021.
  • Publication and promotion of positive action journeys with the view to having more employers using positive action measures.
  • FWF guidance will be available online in January 2021, including good practice examples, to help employers adopt appropriate practice. Officials are working to develop a monitoring and measurement framework to gather information about the change and impact for individuals and organisations.
  • Initial draft of Fair Work race equality paper and circulated to stakeholders for comment (January 2021), further drafting and final publication (February 2021).
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:
  • evidence how different minority ethnic groups are represented in an organisation, across different pay bands;· enable employers to understand if there are unfair disparities and help drive strategies for the recruitment, retention and progression of minority ethnic groups.
Building on the Toolkit, we have commissioned work to develop and publish a guide on positive action that public authorities can take to help shape their actions to make a real impact. We are ensuring that it covers the breadth of the employability pipeline from recruitment to retention to progression. This work is being taken forward by CRER and we expect documentation to be produced by the end of this calendar year.

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.
Fair Work Ongoing
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
December 2020
  • The Scottish Government will finalise the programme proposal, including governance structures.
January 2021
  • Ministers will meet with young Black and Minority Ethnic people (14 January) and wider stakeholder group (20 January).
  • We will also hold an initial meeting of the programme board group (Learning Directorate, Race Equality Team, Education Scotland, SQA and ADES) undertake analysis of evidence gathered at stakeholder meetings and establish strategies for engagement with young people and wider stakeholders for the lifetime of the programme.
  • February 2021
  • We will continue to analyse evidence to help inform the summary document which will be developed throughout the remainder of this phase, and into the next, in collaboration with stakeholders. This will have particular emphasis on young people’s participation. The stakeholder network group will also meet for the first time.
March 2021

A summary document will be published containing identified actionsApril 2021
  • Implementation of actions will be commenced as set out in the summary document, supported by action oriented sub groups.
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:
  • School leadership and Professional Learning
  • Diversity in the Teaching Profession and Education Workforce
  • Curriculum Reform
  • Racism and racist incidents in Schools
The Curriculum Reform SubGroup of the Race Equality and Anti-Racism in Education Programme has been established to consider and identify actions that will promote and embed race equality and anti-racism in the curriculum in a meaningful, effective and sustainable way, contributing to the wider programme.

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.
  • We understand the first meeting of the ESSM steering group will be in early January. We expect the initial meetings to be held monthly while the discussion focuses on the understanding and analysis of the existing relevant data sets.
  • By May 2021 – we expect the national consultation to be ongoing, and it is possible the evaluation stage may be beginning.
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.
  • Completion of mandatory requirement to core records set, primarily hospital episodes, will be nearing completion in February, and regular reporting on completeness will commence from February.
  • Mandatory requirement for submission of patient ethnicity from Health Board systems to national databases is now complete for the set of Scottish Morbidity Records covering inpatients, outpatients, mental health and maternity admissions.
  • Quarterly data quality reports are now being published by Public Health Scotland showing a full breakdown of all the ethnicity codes recorded on national databases including more refined reporting of ‘refused’ and ‘unknown’ codes.
  • Ethnicity is now recorded on Intensive Care Unit (ICU) admissions data collected by the Scottish Healthcare Audits team.
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.
  • Completion of mandatory requirement to core records set, primarily hospital episodes, will be nearing completion in February, and regular reporting on completeness will commence from February.
  • Ethnicity linked to CHI number will be available by the end of 2022 when the new CHI Enterprise Master Patient Index (EMPI) is scheduled to go live.
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.
  • Recognising the need for more robust ethnicity data in this area, Public Health Scotland (PHS) receive a data submission on social care from local authorities that includes ethnicity as a mandatory field. Work is ongoing to integrate this data collection with the wider social care system and to involve relevant bodies such as Local authorities, COSLA and the improvement service.
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.
  • Completion of mandatory requirement to core records set, primarily hospital episodes, will be nearing completion in February, and regular reporting on completeness will commence from February.
  • We will be providing breakdowns for equality groups in the publication of the pooled core survey questions data for 2020. Due to the pandemic this data was collected via phone rather than face to face, therefore some breakdowns may not be possible due to low sample sizes. We will be working with the Equalities Unit to make judgements on what appropriate groupings we could use if sample sizes are too low.
  • Work is ongoing to establish how to reduce bias in core survey response rates to ensure the data is representative of Scotland’s population.
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.
  • Public Health Scotland set up and chaired a workshop of key stakeholder organisations in January to discuss responsibilities around ERG recommendations. Subsequently a Primary Care Short Life Working Group of key partners, including GP representation, was set up.
  • Further discussions are necessary to understand ownership of some actions including workforce and social care especially where relevant organisations were not involved in ERG discussions.
  • The Health Equalities Team was established in March 2021 and is expected to be fully staffed by the end of the year. The team will provide leadership and coordination to equality activities across DG Health & Social Care going forward, with an explicit focus on leading the development of an overarching policy around health ethnicity data collection and use.
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.
  • Completion of mandatory requirement to core records set, primarily hospital episodes, will be nearing completion in February, and regular reporting on completeness will commence from February.
  • The collection of ethnicity data at the time of registration has been agreed to be implemented in principle by the British Medical Association Scotland.
  • Further work to develop the plan for implementation will form part of ongoing work.
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:
  • Strengthened relationships with the African Council to better understand the needs of their communities and how best to support them through Covid.
  • Jambo! Radio Q&A/Interview SG National Clinical Director to discuss the Covid Concerns of those with African and Caribbean Heritage
  • Local partnerships have led to vaccination clinics in mosques, African churches and community centres, gurdwaras and venues used by the Chinese community.
  • Eastern European charity based in Edinburgh, Feniks, hosted a Q+A session with SG National Clinical Director for the Polish community. The session focussed on issues and concerns relating to the vaccine and the session was streamed on Facebook and Zoom and has been made available to re-watch.
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.
Not reported.
  • The forthcoming reform of social care offers an opportunity to build in a solid and sustainable system of data recording for this sector.
  • Baseline work has taken place to establish the current position, the roles and responsibilities of public service organisations.
  • Analysis by ethnicity and other protected characteristics of responses to the 2020 Health and Social Care Staff Wellbeing Survey is underway and will be completed by autumn 2021. The analysis will also consider intersectionality.
  • The Survey asked 13 questions about overall well-being and staff experience of working during the COVID-19 pandemic. The survey also asked staff what was most worrying them and what was supporting them.
  • In total 83,656 Health and Social Care staff took part in the survey. Typically over 90% of those completing the survey opted to provide answers to the demographic questions. This is far higher than the numbers of staff who disclose ethnicity and other data to their employers.
  • The results of this analysis will help us provide more targeted wellbeing and other support to minority ethnic staff across health and social care.
  • Demographics questions, including on ethnicity, have been included in the 2021 iMatter Health and Social Care Staff Experience Continuous Improvement Model questionnaire for the first time. iMatter provides a team-based tool for measuring employee engagement levels, and putting in place an action plan to deliver improvements in Health and Social Care. The iMatter questionnaire is run annually.
  • The 2021 survey is set to run in Autumn 2021. The national report with basic demographic information will be available in January 2022.
  • The demographic questions will replicate the 2022 Scottish Census questions, meaning that direct comparisons of the workforce to the population can be made.
  • The demographic questions will replicate the 2022 Scottish Census questions, meaning that direct comparisons of the workforce to the population can be made.
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.
  • Discussions have taken place with NES on its role in taking forward this recommendation. Health Boards also have a role as they would collate the data on pay bands and from recruitment/promotion exercises. Scottish Government would provide oversight.
  • A work stream will begin later in 2021 to implement this recommendation. The development and agreement of standards for data collection and presentation will take longer than the timescale allowed for within the ERG report.
Health Workforce Ongoing
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.
  • There have been further enquiries about the collection of such data. An opportunity has arisen, with the publication of the Feeley report on social care, and the proposal for a national care service, to reform the system and incorporate an effective workforce data system. A consultation on the national care service is due to be published shortly and it is our intention to build in to the plans the means to implement the recommendation.
  • Further information included under Recommendation 11 (NHS Workforce Data).
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:
  • A dashboard is created by the Scottish Government to report regularly on the impact of decisions made by the public bodies on minority ethnic people and communities during the COVID-19 pandemic, this should also include data from the disruption to health and social care (second-order effects), and financial poverty (third-order effects).
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.
  • Work is ongoing to link impact data from COVID-19 to the National Performance Framework. In addition, Public Health Scotland has continued to report on ethnic inequalities in risks of COVID, most recently in March 2021, including the comparison of wave 1 and wave 2 of COVID-19. In addition monthly reporting of vaccination uptake by ethnicity has commenced.
  • Planning is underway for an annual ethnic inequalities report in Autumn 2021, focusing on pandemic impact in the first instance. Key to implementing this are ensuring that there are strong links to other outputs such as NPF and Equality evidence finder.
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
  • The Scottish Government cannot set objectives for NHS Chief Execs as these are set by NHS Chairs, in their independent scrutiny and assurance roles.
  • Work is underway to set an anti-racist and wider equality objective for Chairs, focussing on the visible support of Chief Execs in giving minority ethnic staff a voice, dedicated resources and time (through staff networks) to shape anti-racist policies and initiatives.
  • The update to Systemic Recommendation 10 (Corporate Accountability) is applicable here. CRER has been commissioned to identify examples of anti-racist performance objectives with proposed performance measures that could be utilised by Scottish Government and public bodies across Scotland and will be invited to present their findings to People Directorate in September.
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.

NPF indicators

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.
? Ongoing


Email: charlie.goodwin-smith@gov.scot

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