Independent Advocacy Service: equality impact assessment

Equality Impact Assessment for change of provider for the Independent Advocacy Service

Title of policy

Change of service provider for the Independent Advocacy Service from 31 January 2026.

Summary of aims and desired outcomes of the policy

This policy is a continuation of an existing service which gives a statutory right to access independent advocacy for disabled people engaging with the Scottish social security system, as set out under Section 10 of the Social Security (Scotland) Act 2018. Delivery standards are already set through legislation and subsequent advocacy services standards. The updated contract strengthens the requirements for delivering an independent, person‑centred and rights‑based advocacy service that empowers disabled people to understand and exercise their rights, participate fully in decisions, and achieve fair outcomes.

The policy contributes to the Scottish social security system’s principles of dignity, fairness and respect, and promotes national outcomes relating to human rights, inclusion and improved access to public services. The updated requirements ensure the service is accessible, culturally competent and responsive to the needs of those who have the statutory right to access the service.

Directorate: Social Security

Division: Social Security Policy

Team: Supporting Access to Social Security

Executive summary

A full EQIA was undertaken because the contracted provider for the Independent Advocacy Service is changing from 31 January 2026. However, the policy aim itself remains unchanged. Therefore, the statutory duty to provide independent advocacy support for disabled people in Scotland continues in full and the core purpose and function of the service are unaffected. What has been updated are the contractual requirements that govern how the statutory service will be delivered. The EQIA therefore examined how these updated requirements — rather than any change in policy intent — could strengthen equality outcomes, improve accessibility, and better address the needs of disabled people and those with intersecting protected characteristics. The assessment considered all nine protected characteristics under the Equality Act 2010, as well as the three Public Sector Equality Duty (PSED) needs.

Evidence for the EQIA drew on a wide range of sources to ensure a robust and comprehensive assessment. This included extensive stakeholder engagement with Disabled People’s Organisations (DPOs), advocacy providers, representatives of seldom‑heard groups and Social Security Scotland staff, who provided detailed insight into barriers, and enablers across protected characteristics and helped inform the tender development process. The assessment also incorporated published research on barriers to take‑up among protected characteristic groups and seldom‑heard communities, including an evidence review examining the experiences of seldom‑heard groups within the Scottish social security system. In addition, service usage data from the current contract, including quarterly monitoring reports from VoiceAbility, offered valuable operational evidence on patterns of access, support needs and adjustments provided. Finally, the EQIA drew upon Scottish Government analytical work, including demand modelling and equality evidence, to understand anticipated future need and ensure the updated contractual requirements were informed by demographic projections and system‑wide learning. The framing exercise and evidence sessions informed the development of the outcomes framework, management information (MI) requirements, and service design commitments embedded in the tender specification and contract.

Key findings

• Positive impacts were identified across all protected characteristics, particularly for disabled people, who are the primary statutory beneficiaries.

• Barriers such as digital exclusion, language and cultural gaps, stigma, and confusion between advocacy and advice were highlighted.

• Contractual mitigations include multi-channel access (phone, digital, paper, in-person), inclusive communication standards, interpreters and alternative formats, WCAG/PSBAR compliance, non-instructed advocacy, and targeted outreach to seldom-heard groups.

• Mandatory equality, anti-racism, and trauma-informed training for staff, alongside robust MI collection and quarterly equality reporting, will enable continuous improvement and responsive adjustments.

Recommendations

The EQIA has shaped the tender for the new contract and subsequent contract requirements by embedding equality considerations into the service design, governance, and evaluation framework. No major changes to the policy aim were required, but enhancements were made to delivery standards, monitoring requirements, and outreach commitments. Additional costs for accessibility measures, training, and outreach have been factored into the contract. Ongoing monitoring will include quarterly equality reports, annual public impact reporting, and a formal evaluation against the outcome’s framework.

By grounding the tender development process in stakeholder engagement and equality evidence, the policy is expected to deliver improved access, empowerment, and choice for disabled people and those with intersecting protected characteristics, helping to eliminate discrimination, advance equality of opportunity, and foster good relations across communities.

Background

The policy fulfils a statutory duty under Section 10 of the Social Security (Scotland) Act 2018 to provide independent advocacy for disabled people engaging with the Scottish social security system. This duty was established following the devolution of certain social security powers to Scotland under the Scotland Act 2016, which led to the creation of Social Security Scotland and the legislative framework for devolved benefits in Scotland through the development of the 2018 Act.

Independent advocacy provision for disabled people is a key aspect of the Scottish social security system. It ensures that disabled people can understand and exercise their rights, participate fully in decisions, and achieve fair outcomes. Section 11^[1] of the 2018 Act also requires Scottish Ministers to develop and publish service standards that apply to this support. These ‘Advocacy Service Standards’ set out the behaviours and requirements for delivering of advocacy in a way that upholds rights for disabled people. This service is therefore critical to not only upholding statutory duties set out in the Social Security (Scotland) Act 2018 but also for delivering a system for disabled people based on dignity, fairness, and respect.

Since the launch of the service in January 2022, VoiceAbility has delivered independent advocacy under contract with the Scottish Government. That contract is now coming to an end on 31 January 2026. This required a new procurement exercise to ensure continuity of this statutory service. The new contract introduces enhanced contract requirements designed to strengthen accessibility, cultural competence, and equality monitoring. Advice Direct Scotland (ADS) will be the new provider of the service from 31 January 2026.

The policy directly affects disabled people who require advocacy support to engage with Social Security Scotland. It also impacts carers and families of disabled people, advocacy workers employed by the provider, and Social Security Scotland staff who refer clients to advocacy services. Indirectly, it affects third-sector organisations and equality stakeholders who collaborate with the service provider.

The development process involved a full procurement exercise to appoint a new service provider for the period 2026–2028. Extensive stakeholder engagement—including Disabled People’s Organisations (DPOs), advocacy providers, Social Security Scotland staff, and equality organisations shaped the tender specification, outcomes framework, and management information requirements. These discussions ensured that the updated contract requirements address accessibility, cultural competence, and equality monitoring from the outset.

The Scope of the EQIA

The Equality Impact Assessment considered all nine protected characteristics under the Equality Act 2010: age, disability, race and ethnicity, sex, pregnancy and maternity, religion or belief, sexual orientation, gender reassignment, and marriage and civil partnership. In addition to these characteristics, the assessment applied the three Public Sector Equality Duty (PSED) needs: eliminating discrimination, advancing equality of opportunity, and fostering good relations between people who share a protected characteristic and those who do not.

The analysis also recognised intersectionality, acknowledging that individuals may experience multiple, overlapping disadvantages. For example, older women with a disability from minority ethnic backgrounds, or disabled parents, may face compounded barriers to accessing advocacy and social security support.

Approach and Methods Used to Assess Impact

The EQIA adopted a qualitative, evidence-led approach supported by stakeholder engagement and thematic analysis. Data collection combined various strands:

1. Stakeholder Engagement: Nine structured workshops were held between February and March 2025 with advocacy organisations, Social Security Scotland operational teams, Disabled People’s Organisations (DPOs), and representatives of seldom-heard groups. These sessions explored barriers and enablers to accessing independent advocacy and social security benefits.
2. Published Research: The assessment incorporated findings from published research, including the ScotCen review of seldom-heard groups within the Scottish social security system and protected characteristic group specific research within the barriers to take-up of social security context. This provided a robust evidence base on systemic barriers such as stigma, digital exclusion, language and cultural challenges, and complexity of processes.
3. Service usage data from existing contract: Quarterly monitoring data from the current service provider (VoiceAbility) was used to understand real‑world patterns of access, regional demand, Equality Act support‑need profiles, referrals, and operational barriers. This data helped identify where disabled people and seldom‑heard groups experience accessibility challenges and where stronger adjustments or targeted outreach may be required.
4. Scottish Government Analytical and Modelling Work: The EQIA also drew on Scottish Government demand modelling and equalities analysis, including demographic projections and caseload forecasting. This work helped assess future demand for advocacy, understand intersecting equalities trends, and ensure that updated contractual requirements are responsive to anticipated needs across protected characteristics.

The methodology focused on identifying both barriers and practical enablers by applying thematic analysis to workshop notes and comparing these insights with findings from published research, monitoring data from the current provider, and relevant Scottish Government analytical and modelling work. This triangulated approach ensured that the assessment was grounded in lived experience of the Scottish social security system as well as in broader evidence about systemic barriers to take‑up. It also enabled officials to analyse existing service data, identify gaps in equality monitoring, and ensure that the updated contractual requirements were informed by a comprehensive understanding of how different groups experience and access independent advocacy.

Details of Evidence Gathering and Engagement

Stakeholder engagement was central to the EQIA process. Workshops were designed to be participative and inclusive, using breakout discussions and process mapping exercises to capture detailed feedback. Advocacy providers contributed insights on operational challenges, such as role confusion between advocacy and advice, gaps in referral pathways, and training needs. Social Security Scotland staff highlighted issues around internal awareness, knowledge management, and the need for provider-agnostic training modules.

Disabled People’s Organisations (DPOs) and organisations representing seldom‑heard groups provided critical perspectives on accessibility, cultural competence and intersectional barriers. Participants described the impact of stigma and mistrust among minority ethnic communities; digital exclusion among older people and Gypsy/Traveller groups; the challenges faced by people with fluctuating or less visible conditions when evidencing eligibility; and concerns about the accessibility and cultural appropriateness of information. Stakeholders also identified key enablers, such as trauma‑informed practice, co‑located support in trusted settings (e.g. health or community venues), simplified processes, and targeted awareness activity delivered through trusted intermediaries.

The engagement process also captured feedback on continuous improvement of the current advocacy contract. The findings informed the tender specification, outcomes framework, and management information requirements embedded in the new contract. Feedback also included recommendations for clearer referral criteria, champions networks within Social Security Scotland to be reconvened and robust monitoring frameworks to track engagement with underrepresented groups.

The engagement findings were complemented by published research, including the Scottish Government’s evidence review of seldom‑heard groups, and by service usage data from the current provider. Quarterly monitoring reports from VoiceAbility between 2022-2025 provided operational insight into patterns of access, support‑need profiles, adjustments provided, and barriers encountered across regions and population groups. This was further supported by Scottish Government analytical work, including demand modelling and equalities analysis, which helped identify likely future pressures and highlighted where enhanced contractual requirements could strengthen accessibility and monitoring.

Together, this evidence informed the development of the tender specification, outcomes framework and updated management information requirements. Stakeholders also provided feedback on areas for continuous improvement in contract delivery, including clearer referral criteria, reconvening internal advocacy “champion” networks within Social Security Scotland, and strengthening equality monitoring to better track engagement with under‑represented groups.

Key Findings

Overview of evidence gathered and analysed

The EQIA drew on multiple sources, including stakeholder engagement workshops with Disabled People’s Organisations (DPOs), advocacy providers, Social Security Scotland staff, and equality organisations representing seldom-heard groups. National research on barriers and enablers to accessing social security was also reviewed as well as quarterly monitoring data from the current provider. Evidence highlighted recurring themes such as digital exclusion, language and cultural barriers, stigma, complexity of processes, and confusion between advocacy and advice. These barriers often intersect with other protected characteristics, compounding disadvantage.

Summary of impacts by protected characteristic

• Disability: Strong positive impact as the policy upholds a statutory right and embeds rights-based, person-centred advocacy. Risks of indirect discrimination (e.g., inaccessible formats) are mitigated through inclusive communication standards, assistive technology, and non-instructed advocacy.
• Age: Positive impact through multi-channel access and in-person default, addressing digital exclusion for older adults and flexibility needs for younger parents.
• Sex: Women and lone parents are more likely to engage with social security and face caring constraints. Flexible scheduling, in‑person options, and trauma‑informed practice help address these barriers. Evidence also indicates lower take‑up among men, so the contract requirements advance equality of opportunity for all genders through sex‑disaggregated MI, neutral and inclusive outreach, and partnership work with individual organisations that support men and women.
• Pregnancy and Maternity: Positive impact via home visits, multi-channel access, and rapid referral handling to support parents at key benefit trigger points.
• Race: Barriers include language and distrust of systems. Mitigations include interpreters, translated materials, anti-racism training, and targeted outreach to minority ethnic communities.
• Religion or Belief: Adjustments for observance needs and voluntary disclosure safeguards reduce discrimination risk.
• Gender Reassignment: Positive impacts through opt‑in data collection, EDI and anti‑stigma training, inclusive messaging, and person‑centred practice. Privacy and disclosure concerns are addressed through consent‑based processes, separate advocacy records, and strong digital/cyber security requirements.
• Sexual Orientation: Positive impacts through opt‑in data collection, inclusive communications, and EDI training supporting respectful interactions. Privacy concerns are mitigated through consent‑based data handling, confidentiality safeguards, and secure digital systems.
• Marriage and Civil Partnership: No differential impact identified.

Intersectional and human rights impacts

The EQIA identified that disabled people who also belong to other protected or seldom-heard groups (e.g., minority ethnic communities, refugees, carers, survivors of abuse) face compounded barriers. The contract addresses this through targeted outreach, culturally competent practice, and robust equality monitoring. The policy supports human rights by enabling disabled people to exercise their statutory entitlement to advocacy and participate fully in decisions affecting them.

Data gaps and limitations

Baseline data on some characteristics (e.g., gender reassignment, sexual orientation, religion or belief) is limited. To address this, the contract mandates individual-level MI collection across all protected characteristics and seldom-heard categories, with opt-in for sensitive data. Quarterly equality reporting and continuous improvement processes will ensure gaps are monitored and mitigated.

Recommendations and Conclusion

The EQIA process directly shaped the new Independent Advocacy Service contract by embedding equality considerations into service design and governance. Key actions include:

• Multi-channel access (phone, digital, paper, and in-person) and in-person as default to address digital exclusion and geographic barriers.
• Inclusive communication standards, interpreters, alternative formats, and WCAG/PSBAR compliance to ensure accessibility for all users.
• Provision of non-instructed advocacy for individuals unable to articulate their wishes.
• Targeted outreach to seldom-heard groups, including minoritised ethnic communities, young parents, socially isolated older adults, and survivors of abuse.
• Mandatory equality, anti-racism, and trauma-informed training for all staff to promote cultural competence and reduce stigma.
• Robust management information (MI) requirements to monitor uptake and outcomes across all protected characteristics and seldom-heard categories.

These measures address barriers identified during evidence gathering, such as digital exclusion, language gaps, stigma, and complexity of processes. They advance equality of opportunity by ensuring disabled people – and in particular those who are disabled with intersecting protected characteristics – can access advocacy in a way that meets their needs. They also foster good relations by embedding inclusive practice and transparency through public reporting.

Equality monitoring and review schedule

The policy will be monitored through a robust governance framework embedded in the contract. The service provider will submit quarterly equality reports containing disaggregated management information (MI) on all protected characteristics and seldom-heard groups. A continuous improvement cycle will use MI trends and stakeholder feedback to identify and address emerging issues. Progress will be transparently reported through an annual public impact report, and a formal evaluation against the outcomes framework will take place within the first two years of the contract. In addition, ongoing KPI monitoring agreed during mobilisation will be reviewed at quarterly contract management meetings to ensure compliance and drive service improvements.

Conclusion

The EQIA has strengthened the policy by ensuring that enhanced equality and human rights considerations are embedded in every aspect of service delivery. By grounding the design in lived experience and robust evidence, the policy is expected to deliver even better outcomes for disabled people and those with intersecting characteristics, further helping to eliminate discrimination, advance equality of opportunity, and foster good relations across communities.