Scams prevention awareness and enforcement strategy: equality impact assessment

Scams Prevention Awareness & Enforcement Strategy: Equality Impact Assessment – Results

Title of Policy

Scams Prevention Awareness & Enforcement Strategy

Summary of aims and desired outcomes of Policy

The aim of the Scams Prevention, Awareness & Enforcement Strategy is to establish Scotland as an inhospitable environment for scammers to exploit people, where people feel safe against the risk posed by scams and can readily access effective support to meet their needs.

The Strategy will facilitate a more coordinated approach to tackling scams in Scotland, and deliver improved outcomes for people in Scotland through the introduction of a new strategic framework focussed on three pillars:

(1) Prevention and disruption;
(2) Awareness raising, education and access to support; and
(3) Enforcement Action

The Strategy's desired outcomes are to ensure:

• Our people are informed and are able to take control when they become exposed to scams and build resilience against falling victim to a scam.
• Provide a clear understanding of who to go to, to access and advice and support.
• Victims of scams know who report the crime to, when and how.
• Build confidence and trust in communities where people's rights and interests are being protected.

Directorate: Division: team

Directorate for Energy and Climate Change.
Consumer, Competition and Energy Company Services

Executive summary

The Equality Impact Assessment (EQIA) was undertaken to help measure the impact of the development of a Scams Prevention, Awareness & Enforcement Strategy ("the Strategy") on equalities groups.

The EQIA process identified

• a lack of scam related information or Scotland specific data available evidencing the impact of scams on different protected characteristic groups.
• no one is immune from the risk that scammers pose and scams are not constrained by geographic, demographic or socio-economic boundaries.
• a need to embed scams literacy into wider society, through drawing on the reach, trust and legitimacy of education providers, including schools and training provided at work.
• a potential benefit in engaging Race and Religion or Belief groups to help promote awareness and improve understanding of scams.
• a particular opportunity to raise awareness and educate older people, as as scammers target older people - predominantly by telephone.
• opportunities to promote educational awareness among young people because of their increasing use of social media and online activity.
• the need to engage disabled people to ensure scam prevention and awareness activity meets the needs of different groups and ensure support services are accessible by all.

To address the issues identified above the following actions are now underway:

• Continued engagement with the Scams Prevention Partnership & Advisory Group ("Advisory Group") - membership is made up of key stakeholders who deliver scam advice services, awareness campaigns and prevention interventions and enforcement in Scotland. Members include Police Scotland, Trading Standards Scotland, Advice Direct Scotland, Citizens Advice Scotland and more.
• Ongoing activity with stakeholders representing equalities groups including Age Scotland, East Renfrewshire Prevention Team, YoungScot Disability Equality Scotland and deafscotland.

And continued engagement with key strategic partners to support implementation of our new shared strategic framework for tackling scams in Scotland. This will focus on: Prevention & Disruption, Education and Awareness, and Enforcement. Under the framework we will take forward a number of actions including:

• Development of a shared Anti-Scams Communications Plan that takes into account communications reach and appropriateness of content of key messages in order to meet different groups' needs. This may lead to partners agreeing some type of strategic messaging protocol for different groups of individuals in vulnerable circumstances.
• Through development of a Strategic Education Action Plan we will also work with partners to consider any gaps in existing educational materials and guidance according to the needs of different groups at high risk of being scammed, or impacted by them.
• Future on-going engagement with a range of relevant stakeholders that can champion the voice of the victims of scams will also be achieved through establishment of the formalised Scottish Scams Prevention Partnership.

Background

Research and stakeholder engagement conducted to date suggests that the protection of consumers against the impacts of scams activity requires a multi-pronged approach, prevention, awareness and enforcement – consumer protection is reserved, and regulation alone is not sufficient. Therefore the purpose of the Scams Prevention, Awareness & Enforcement Strategy is to reduce the harms caused by this type of crime.

Scams cannot be treated as a uniquely consumer-focused issue, their consequences are more wide-ranging and tackling them requires collaboration across different policy areas and stakeholder groups, including: Social Justice, Community Safety, Organised Crime, Cybercrime and third sector.

The Strategy aims to establish Scotland as an inhospitable environment for scammers to exploit people, where people feel safe against the risk posed by scams and can readily access effective support to meet their needs.

By delivering the strategic framework, we will contribute positively to many of the National Outcomes in the National Performance Framework and in particular:

• Children and Young People – We grow up loved, safe and respected so we realise our full potential
• Communities – We live in communities that are inclusive, employer, resilient and safe.
• Education – We are well educated, skilled able to contribute to society
• Health – We are healthy and active and our public services are high quality, efficient and responsive to local people's needs

The Scope of the EQIA

The EQIA assesses the development of the Strategy against the three needs of the public sector equality duty, namely to:

• Eliminate discrimination, harassment and victimisation;
• Advance equality of opportunity; and
• Foster good relations

It does so with respect to the nine protected characteristics of Age, Disability, Sex, Pregnancy and Maternity, Gender Reassignment, Sexual Orientation, Race, Religion or Belief and Marriage and Civil Partnership.

The following stakeholders have been consulted as part of the EQIA process: Age Scotland, YoungScot, Disability Equality Scotland, East Renfrewshire Prevention Team and deafscotland.

Key Findings

The EQIA for The Scams Prevention, Awareness & Enforcement Strategy has highlighted potential impacts for two characteristic groups, age and disability, where external engagement is required to explore impacts further to eliminate discrimination, promote equality and foster good relations.

We also recognise the benefits of engaging Race and Religion or Belief groups to help promote awareness and improve understanding of scams.

There is limited data available to enable a full assessment of impact of the Strategy on equality groups. The Strategy in and of itself will not adversely affect any group of people. It will investigate gaps within, and consider future actions to develop the evidence base. This will enable us to collate and analyse information across society, including equalities groups. As our understanding of the scams landscape improves, we will be able to fully assess the impact of our policy on all equalities groups, which will result in positive outcomes.

Recommendations and Conclusion

Actions to address the equality gaps in relation to scams in Scotland can be linked to the strategic framework that seeks to introduce a more integrated approach across scams prevention and support landscape.

• A newly established Scottish Scams Prevention Partnership ("the Partnership") will be embedded as a standalone, formalised partnership group – with a clear identity and position within the wider stakeholder landscape – to act as a collective voice when it comes to communicating both key preventative messages on scams to members of the public; and advocating for further change in policy or operational approaches as they relate to all three pillars of the strategic framework.

Strategic Framework
(1) Prevention & Disruption
We will work with partners across private, public and third sectors to attempt to proactively deter, disrupt and, ideally, stop scams from reaching victims, using digital technology, innovation, and improving processes and protocols.
(2) Education & Awareness
Focus on enabling people through building resilience, vigilance, knowledge and skills to avoid the risk that scams pose
(3) Advice, Support & Enforcement
Work with frontline advice services and enforcement bodies to streamline the scams reporting and advice landscape, including through facilitating better data and intelligence sharing, in order to develop a "whole person, whole system" approach to provision of support and effective intervention.

• Development of a shared Anti-Scams Communications Plan that takes into account communications reach and appropriateness of content of key messages in order to meet different groups' needs. This may lead to partners agreeing some type of strategic messaging protocol for different groups of individuals in vulnerable circumstances.
• Through consultation with the new Partnership, we will develop a set of specific actions to address any gaps in existing education materials and approaches available to people across different settings (from schools to work to communities) and risk groups, to build resilience against scams and their impacts. Such collaboration will provide scope to involve representatives from equalities groups.
• To inform considerations of the Partnership moving forwards we will also be undertaking a programme of public engagement that will provide a further opportunity to engage with a range of people across Scotland to better understand the challenges faced in building resilience against scams, and/or reporting scams and accessing appropriate support when things go wrong.
• Working with colleagues organising the Strategy launch events will include further collaborative work with partners to identify opportunities to engage equality groups.

The EQIA has helped identify specific groups that we want to work further with during the implementation phase of the strategic framework. We will also seek to work with stakeholders to ensure the strategy's implementation seeks to maximise positive impacts related to Age, Race, Faith and Disability, which will ultimately help us deliver better outcomes for all people and communities.