ScotAccount: equality impact assessment

2.0 Key findings

The EQIA analysis considers both positive opportunities and risks of indirect discrimination, alongside intersectionality with socioeconomic disadvantage.

Age

(i) Young people

Young people can be digitally excluded from lack of access to digital equipment and Wi-Fi, lower levels of digital skill and trust in digital routes.^[13]

Young people using ScotAccount could also be affected by ID poverty, with less ownership of the traditional documents required to prove who they are and less of a digital footprint in the real world to evidence that their identity is real and can be verified.

(ii) ID poverty

Young people hold less of the biometric proofs required to verify that the person claiming the identity is entitled to use it in the digital identity verification process. The most widely accepted biometric proofs for identity verification are passports and driving licences.

(iii) Passport ownership

82% of people responding to Scotland’s Census^[14] said they had a passport. In the 25 to 34 age range, ownership was reported as 91% (630 k), and 89% (518 k) in the 16 to 24 age range.

(iv) Driving licence and provisional driving licence ownership

In Scotland only 39% of 17 to 19-year-olds hold a driving licence. Within this group there is also evidence of higher rates of ownership amongst white British and white Scottish people than other ethnic groups. There is also a correlation between rates of ownership of a driving licence and higher income groups, associated with escalating costs involved in getting on the road.^[15]

There are multiple complex reasons why some individuals may not have a driving licence or passport, including: it has expired, been lost or damaged, or that the individual is unable to purchase a new one due to associated costs or requirements. People may also lack the necessary additional documents to apply for a driving licence or passport, including not having proof of an address or a birth certificate.

To mitigate this ScotAccount introduced the use of the Young Scot National Entitlement Card^[16] as a biometric proof. Unlike a passport and driving licence, this is a no-cost card available to 11 to 26-year-olds living in Scotland. In 2025, a total of 700k Young Scot NEC cards have been issued to young people aged between 11 and 26.^[17]

People who have not conducted the financial transactions used to build credit files could have difficulty completing digital identity verification checks, as they involve a light credit check. The possession of a bank account and some type of digital footprint such as: council tax payments, being named on mobile phone contracts, paying utility bills or existence on an electoral register is required to pass this proofing process. Younger people may lack sufficient credit history altogether, as they have lived with parents and/or been fully supported by adults.

Recent research has also highlighted the specific circumstances facing care-experienced young people,^[18] showing that they have disproportionate use of digital routes due to difficulties obtaining Wi-Fi and mobile phones. Many care-experienced young people are less likely to know a trusted adult who can initiate a mobile phone contract on their behalf before they are 18. After the age of 18, limited or absent credit history can further restrict their ability to secure broadband or mobile contracts. The study also found that many care-experienced young people lacked foundation digital skills due to limited digital exposure, often being part of households where the internet is unavailable or controlled, and from environments where adults are digitally excluded.

To mitigate this, the ScotAccount programme is actively exploring a range of alternative data sources to establish if an identity exists in the real world, including data established without a prior need for financial transactions, such as public service data, which will widen inclusion.

The Scottish Government digital identity programme has also commissioned a Civtech challenge^[19] to find solutions for those who may be unable to use ScotAccount. Solutions are to focus on those who do not hold traditional documents for online identity proof (passport and driving licence) and who may need additional support using digital systems.

The age range for ScotAccount service users is still to be determined. However, the ScotAccount sign-in service is available for anyone who has an email address. The ScotAccount identity verification service (IDV) is primarily used by people aged 18 and over, as it requires a digital footprint in the real world, which those under 18 generally lack. The service anonymously monitors user age ranges as part of inclusion reporting for continuous improvement. This also supports the impacts of new strategies, such as alternative IDV routes, aimed at widening inclusion.

(v) Older people

Evidence indicates that some older people have lower digital skills, less trust in digital services and devices, less ownership of devices, and/or own devices which are older. Those with the lowest digital capability are most likely to be aged 70+ (54%) or earning less than £20,000 a year (41%).^[20]

Older people are also less likely to own a passport or driving licence for biometric identity verification.

According to Scotland’s Census 2022,^[21] approximately 3.7 million people (65.5% of the population in Scotland) held a UK passport. It was also noted that older adults in Scotland, particularly those aged 65 and over, are less likely to hold a passport compared to younger age groups.

Additionally, individuals living in rural areas and those from lower-income households are also less likely to have passports.^[22]

While the number of young people aged between 16 and 25 holding a full driving licence has decreased, the number of people aged over 70 holding a full driving licence has increased, while people aged 80 and over with a full driving licence increased by more than 100,000 and now stand at 1,788,280.^[23]

Age may also influence a person’s ability to access the technology required for digital services. Fewer people aged 65 or above own mobile phones, compared with all adults.^[24] Digital confidence is also lower in these age groups.^[25]

ScotAccount policy is to make the service simple to use and accessible. The reading age for ScotAccount is 8 years old. Extensive user research has considered user feedback on the clarity of the service user journey.

An intersectional relationship between age and poverty also factors in digital exclusion and is repeated in the findings of the Scottish Household survey, which found that only half of those aged over 60 in the most deprived areas used the internet, while 83% of those aged over 60 in the least deprived areas did.^[26]

While internet availability and cost are beyond the scope of the digital identity programme, the programme aims to work with partners in Connecting Scotland to support the Scottish Government objectives to improve digital access.

The Scottish Government has a commitment to delivering improved digital connectivity and has a strong track record of delivering successful digital infrastructure programmes in order to close this digital divide. Scottish Government digital programmes including the legacy Digital Scotland Superfast Broadband programme and the live R100 programme are driving connectivity beyond cities and into our most rural communities and have provided over one million faster broadband connections to date.

Affordability is also a barrier to individuals getting online. Broadband and mobile social tariffs are cheaper than standard broadband packages. People can obtain a broadband or mobile social tariff if they are paid Universal Credit, Pension Credit, Employment and Support Allowance, Jobseeker’s Allowance or Income Support. While social tariffs are reserved to the UK Government and are in Ofcom’s remit, the Scottish Government supports wider provision of these tariffs and encourages measures to promote their uptake.

To help ensure that the provision of digital public services does not leave anyone behind, the Scottish Government has sought to tackle digital exclusion through a range of targeted measures. The Connecting Scotland programme has enabled over 61,000 individuals to access devices, internet connectivity, and essential digital skills since 2020, directly supporting their ability to engage with online services.

Work is progressing to establish a Digital Inclusion Alliance, which will bring together partners across sectors to tackle the systemic barriers that prevent people from participating fully in the digital world. Additionally, commissioned research into a Minimum Digital Living Standard for Scotland provides an evidence base to guide future policy, ensuring that digital inclusion efforts are aligned with the real-world needs of citizens as more services transition online.

Scottish Government policy is that people should be able to access public services through the channel that works for them. This might be a digital route, or it might be through face-to-face services or another method. ScotAccount encourages service adopters to maintain offline routes to public services.

(vi) Trust in digital services

Both younger and older people have concerns about scams and tracking which could prevent them engaging with online services.^[27] In particular, older people’s trust in the security of services could prevent some users engaging with digital services and sharing their information online.^[28]

To foster public trust, ScotAccount aligns with the Scottish Government’s Identity Management and Privacy Principles^[29] which outline the need for openness and transparency around how personal data is used, and privacy protected. This helps ensure that respect for privacy is central to the way public services use data and ask users to prove identity or entitlement. Privacy notices and other information governance documentation contain a clear articulation of the legal basis for which the data will be used and be consistent across data controllers and service providers. A key recommendation is the use of clear privacy statements to help people understand the handling of their personal information.

ScotAccount adopts the principles of data minimisation: that personally identifying information is not collected, unless and until a specific purpose is defined. If defined, such a collection needs to be justified, necessary, proportionate and accountability must be demonstrated.

The ScotAccount attribute store asks users to choose whether to save their verified personal information for reuse with other services later. Use of Good Practice Guide 44 medium level of authentication^[30] means that ScotAccount can be confident that it is the same returning user who has control of their account. This means there is no need to repeat checks. This supports the privacy principle “identify only once,” where users will be able to reuse the results of the check for multiple services without needing to repeat the process.

Use of the ScotAccount attributes store is optional, which supports data minimisation principles. Data sharing will only take place when the user is ‘present’ and gives active permission to share individual pieces of information to the public service requesting it.

ScotAccount’s public privacy policy is available and details the commitment to the user^[31] and ScotAccount terms of use.^[32]

ScotAccount is also subject to a robust programme of security governance and standards assessment including the Scottish Public Sector Cyber Resilience Framework (Advanced Tier).^[33]

The ScotAccount digital identity programme team consults with the Information Commissioner’s Office (ICO) to identify any limitations concerning data protection and privacy. The ICO were also members of the Digital Identity Programme Expert Group who advised the programme as it developed.

A core element to the commitment to providing a trusted, safe, and secure digital identity service is compliance with the Good Practice Guide 45 (GPG 45) standards.^[34] This establishes the link between a signed-in user and a real-world identity. GPG 45 standards are essential for transactions where extra confidence in identity verification is needed.

However, meeting high assurance levels, such as GPG standards, to ensure security and trust can be challenging for individuals who cannot provide the information required to meet GPG profiles. Balancing trust, security and inclusion has been a major focus of the programme.

Disability

Disabilities that may affect the user experience of ScotAccount include physical disabilities, mental health conditions, and cognitive impairments, each presenting unique challenges for users.

(i) Age-related disability

Research indicates a potential intersectional relationship between age and disability that increases the risk of digital disadvantage. The prevalence of disability rises with age: around half of people aged over 75 have a disability.^[35]

(ii) Digital exclusion and disability

As with age, digital exclusion is a key consideration for disabled people. Glasgow Disability Alliance reports that 60% of their members feel digitally excluded, and while disabled people may have a smartphone, it may be too old to support certain apps. Some disabled people may use an older model of mobile phone as it meets their accessibility needs and so may not want to upgrade their phone to a new model. As technology changes, some of these systems may not be supported.^[36]

Evidence also shows that 95.9% of global homepages do not comply with internationally recognised accessibility standards.^[37] Disabled people are significantly less likely than non-disabled people to have internet access (65% compared to 88%), and disproportionately low internet access affects disabled people across all age groups.^[38] Moreover, ONS statistics show that the proportion of adults who are recent internet users is lower for those that are disabled, compared with those that are not.^[39] As a result of these factors, evidence suggests that proxy solutions to digital services are sought by many users, particularly older people and disabled people.^[40]

ScotAccount meets best practice Accessibility Standards^[41] and was assessed as compliant to level “AA”^[42] by the Scottish Government Digital Accessibility Team. ScotAccount, as part of the end-to-end Disclosure Scotland service, was also assessed by the Scottish Government Digital Assurance Programme against the Digital Scotland Service Standard.^[43] These standards are designed to ensure that government services are accessible, effective, and work well for everyone who needs to use them.

(iii) Mental health

Research shows that mental health disorders account for 30% of life-limiting long-term conditions amongst disabled adults.^[44] There are intersectional relationships between mental health and poverty affecting digital access and inclusion: 49% of those with above-average mental health have access to the internet compared with 38% of those without internet access.[45] 71% of adults with some form of limiting long-term physical or mental health condition have internet access, compared with 94% of adults with no condition.^[46]

At present there is little evidence on the impact of accessing digital services for people who have been sectioned under mental health legislation. This area could therefore be explored further.

(iv) Socioeconomic status and disability

Disability also varies with socioeconomic status. As research demonstrates, in 2017, 23% of those in the least deprived quintile of the population reported disabilities, compared to 43% of those in the most deprived quintile.^[47]

Race

Language barriers and lack of translations can reduce trust and inclusion. Gypsy and Traveller communities face low internet access and confidence, while ethnic minorities show disproportionate ownership of driving licences. Facial recognition bias remains a concern.

The ScotAccount service is not restricted to people resident in Scotland. Individuals who live outside the UK, but who may be eligible for Scottish public services can also use ScotAccount. For example, people seeking Disclosure Scotland checks prior to working in the UK.

The most recent Scottish census shows that 93.8% of people in Scotland aged 3 and over said they could speak, read, and write English. 75.2% of people born in EU accession countries said they could speak, read, and write English. 88.8% of people born in the Middle East and Asia could speak, read, and write English. The most commonly spoken languages at home other than English and Scots were:

1. Polish (54,186 people)

2. Chinese languages (27,903 people)

3. Urdu (23,394 people)

4. Punjabi languages (23,238 people)

5. French (14,623 people)^[48]

Social Security Scotland research participants described how language barriers made it difficult for them and others they knew to access support. Some participants explained that they struggled to approach a system that only provided information in English, which was not their first language. Others discussed the practical problems of fully understanding information and guidance about eligibility criteria on leaflets, social media, and websites. Several participants argued that multilingual materials would help to show the public that Social Security Scotland was inclusive to different cultures.^[49]

UK Government data shows that adults from the Chinese (96%), Any other Asian background (99%), Black African (96%) and Any other White background (97%) ethnic groups were more likely to use the internet compared to the average for adults in England (92%).^[50] However, the NHS BME Network expressed the view that digital exclusion is high amongst elderly people of ethnic minority groups.^[51]

There is a disproportionate ownership of proof of identity documents related to race. Data from 2022 reported that 55% of black people had a full driving licence, compared with 78% of white people.^[52]

There have been some concerns expressed in the wider digital environment regarding racial bias in facial recognition technology,^[53] which could result in a different experience for Black, East Asian, and American Indian faces compared to white faces. This research also found that black women had the highest error rates in facial recognition tests across all demographics. Companies used by ScotAccount conduct bias monitoring as best practice to mitigate potential impacts.

Gypsies and Travellers without a permanent address or a digital footprint could have difficulty proving who they are online.^[54] Lack of internet access and limited digital skills have also been identified as issues within the Gypsy and Traveller community.^[55]

A 2025 report on digital exclusion in Gypsy and Traveller communities in the UK showed that:

• One in five Gypsy and Traveller participants surveyed had never used the internet, compared to one in ten members of the general population.
• Over half of Gypsy and Traveller participants surveyed said that they did not feel confident using digital technology by themselves.
• Only two in five Gypsy and Traveller participants surveyed said that they used the internet daily, compared to four out of five of the general population.
• Only 38% of Gypsies and Traveller participants surveyed (33% if housed) had a household internet connection, compared to 86% of the general population.^[56]

The report also found that all interviewees who had never accessed the internet were over 40 years old and had low or no literacy. More than half of these participants indicated that limited literacy was their main barrier to using the internet. Other obstacles to digital inclusion mentioned cost, running out of data, poor signal, and the need for additional learning support.^[57]

Gender reassignment

Trans and non-binary people face higher levels of discrimination and hate crime; online access has been shown to reduce stress and vulnerability.^[58] The ScotAccount data minimisation approach helps to reduce bias.

Positive impacts within the gender reassignment category include safer access to services and reduced exposure to prejudice. Negative impacts include difficulties following name changes, as security protocols require creating a new account.

Data shows that there is an overall positive impact from increasing access to online services, with no significant differences in digital participation between adults whose gender identity was the same as their sex registered at birth and adults whose gender identity was different from their sex registered at birth.^[59] Providing routes to services was seen as having a positive impact by reducing stress experienced by some people who did not want to engage with face-to-face services.

Ownership of identity verification documents within this protected characteristic is lower.^[60] Stonewall and LGBTQ+ foundation research shows that matching existing biometric proofs with facial recognition software was an issue.^[61]

Religion and belief

No significant impact was identified within this characteristic. Some digital services which have short timeout periods can be problematic during Ramadan, when people have religious observance that could alter their daily schedule, preventing the ability to respond within short time periods.

ScotAccount identity verification process is available 24/7 with an average journey time for completion of under ten minutes, supporting the user’s schedule.

Pregnancy and maternity

This EQIA is required to look only at discrimination in workplace situations. No evidence was found that demonstrated workplace discrimination in relation to ScotAccount within this characteristic.

A positive benefit could be from the ability to use digital channels, either for work and for access to public services, particularly in rural environments, reducing the need to travel to access services. However, a possible intersectional impact relating to age and socioeconomic status could have a negative impact on access to digital public services. Improving access to digital information and care could be a benefit, especially in rural or underserved areas.^[62]

Sex

No direct difference in digital access was found within this characteristic, but there is evidence of an intersectional relationship between poverty, sex, age, and disability which could impact on digital use of services. A higher number of disabled people are women (34% of women compared to 29% of men) and poverty amongst single female pensioners was higher than amongst men.^[63]

The framing discussion around use cases for ScotAccount mapped the journey for women and girls who have experienced abuse. Access to digital services and the ability to verify identity online could be particularly beneficial for those leaving abusive relationships without paperwork. This approach reduces reliance on physical documents and minimises the need to repeatedly share sensitive information with multiple public services.

However, during the framing discussion it was noted that a digital identity could present an opportunity for coercive control if security information is compromised or shared with an abuser.

Sexual orientation

LGBTQ+ people have concerns about being outed and experience higher rates of hate crime. The availability of digital services could be seen as protective, as the user is not required to visit public buildings to prove identity.

However, there is some evidence that lack of trust in services is an issue. If people do not trust the service, they may not engage with digital/online versions.^[64]

Positive impacts include privacy-protecting online access, reducing exposure to bias. Negative impacts may occur due to lower ownership of traditional identity documents, limiting verification options.^[65]

Marriage and civil partnership (elimination of discrimination only)

No evidence of workplace discrimination in relation to ScotAccount was found, and this characteristic is not relevant outside employment contexts.

Remote and rural and/or island communities

This EQIA has considered impacts of living in remote or rural communities, concluding that where there is a digital access infrastructure there will be a positive benefit from using ScotAccount to access digital public services, rather than travelling to physical locations to access public services.

However, poor (or no) broadband and mobile infrastructure is more likely to be experienced in remote, small towns,^[66] which can mean that those in rural areas face the disadvantage of limited access to physical services as well as those online.^[67]