ScotAccount: equality impact assessment

2.2 Recommendations

(i)Actions implemented

The interim EQIA, along with insights from the embedded ScotAccount User Research team, informed the development of ScotAccount by identifying potential impacts which were then addressed within the delivery programme.

The following actions have been implemented to enhance inclusion and accessibility based on the EQIA findings:

• ScotAccount introduced two-factor authentication using landlines to mitigate potential impact from lower levels of mobile phone ownership amongst older people.
• To ensure accessibility, the ScotAccount interface was designed with a reading age of eight years old.
• ScotAccount was continually tested against best practice accessibility standards and assessed as meeting Web Content Accessibility Guidelines to an “AA” rating.
• ScotAccount engages with service stakeholders throughout development, with early adopters playing a key role in shaping service design.
• Ongoing onboarding includes user research and service design expertise to meet diverse user needs.
• ScotAccount engaged with an expert group in areas of privacy, security, and inclusion, to inform each stage of the programme development.
• In prioritising which alternative proofs to pursue for inclusion, ScotAccount engaged with the Scottish Youth Parliament for insights into young people’s preferences and ideas.
• ScotAccount now includes the Young Scot NEC card for biometric proof.
• Knowledge-based verification was developed as an alternative to biometric data checks, removing the need for passports or driving licences.

In addition to the above actions, ScotAccount is actively developing alternative ways in which people can verify their identity without relying on previous financial transactions. The programme team is working with public sector data owners to identify trusted sources that meet GPG 45 (medium) security standards, with priority given to data sources that support inclusion for impacted groups.

(ii) Mitigating actions

The following actions have been taken to mitigate potential negative impacts, promote equality and meet the PSED needs:

• Where ScotAccount cannot directly influence digital inclusion infrastructure, the team liaises with the Connecting Scotland programme and the Scottish Government Digital Citizen Division to highlight systemic barriers and opportunities for improvement.
• Potential cost implications that may arise from new data-sharing arrangements and public engagement activities are being scoped as part of the programme’s continuous improvement and inclusion strategy.
• ScotAccount sponsored a £650,000 Civtech challenge (9.7) to explore a “vouching solution” which would widen inclusion for people who did not have traditional proofs.
• Scottish Government Digital Citizen Division is sponsoring a £1 million Civtech Challenge (11.9) aimed at providing sustainable solutions for digitally excluded people to overcome barriers accessing key online services. This could attract interest and potential solutions from innovators in local government, private sector or the third sector.

(iii) Monitoring and review

The ScotAccount strategic approach is to source and use reliable data for identity verification to widen inclusion. On the basis of an options appraisal, the ScotAccount team is exploring data sources in the public sector which are not reliant on a history of financial transactions. This is aimed at providing a route for anyone with protected characteristics who could be impacted by socioeconomic factors (i.e. people who have a ‘thin credit file’ and who do not own traditional proofs for biometric checks).

ScotAccount will evaluate these routes through live service monitoring and user surveys.

As previously highlighted, ScotAccount is a privacy protecting service, and the ability to monitor and report on data is limited. The ScotAccount live service data monitoring will include anonymised service user age reporting and postcode to examine socioeconomic inclusion.

The embedded user research team will continue to engage with users and future users for insights. User research gains these insights from user feedback questionnaires which feed into service improvements. ScotAccount is currently exploring how the feedback results could be streamed for equalities monitoring.

As new customers onboard to ScotAccount, the stakeholder engagement strategy includes an understanding of their client matrix and service impact assessments to mitigate exclusion.

The findings of this EQIA will inform the stakeholder engagement strategy to better understand gaps in information and gain insights from people with protected characteristics. This includes joint engagement with service customers, the wider remit of the Digital Citizen Division and the ScotAccount team.

Sign Off Name: Eilidh McLaughlin

Job Title: Deputy Director, Digital Ethics, Inclusion & Assurance

Date: 3 February 2026