Scottish Health Information Integrity Strategy

Strategy Implementation

Aligning with emerging best practice, this strategy focuses on three pillars; leadership and coordination, building Scotland’s resilience to false information and rapid response. Detailed recommendations are set out in the following section.

Detailed Recommendations

Overarching themes

a. A clear understanding of what constitutes false information, and what does not – there are many situations where information is both clearly false and harmful. However, there are many situations in which it may not be clear whether information is true or false, including due to reasonable doubts or concerns. Efforts to address false information – in whatever capacity – must be underpinned by a core definition of what false information is.

b. Building trust is a fundamental aim – trust is vital to the health of our society. The proliferation and reach of false information have further damaged public trust, which has already declined significantly over recent years. Whether via community engagement or public communication, on- or offline, all activities to address the harms of false health information must retain building trust as a core aim. This includes understanding the barriers to trusting health and social care that some communities may face.

c. Work is commenced in areas of greatest need – work should begin in an area clearly affected by false information, such as vaccination and immunisation, and then expanded into other aspects of health and social care as required.

Pillar One – Leadership and coordination

a. Dedicated leadership – the complexity and scope of this subject area, combined with the speed of evidence development and breadth of the stakeholder base necessitate a centralised point of expertise in government that can provide sustained and concentrated leadership to this agenda.

i. Lead – Scottish Government

b. Embedding in organisational governance – strategic implementation and wider activities to counter the proliferation of false health information will be embedded within organisational governance structures.

i. Leads – Scottish Government, Public Health Scotland

c. Working with UK and international partners – Scotland will work with partners across the UK, in other countries and with multilateral institutions including the World Health Organization to gain insight, share learning and ensure that Scottish efforts to support health information integrity are aligned to the latest evidence.

i. Lead – Scottish Government

d. A template for a cross-government response – false information is a whole-society issue that spans well beyond the health domain. This strategy provides a template for other areas of government seeking to address false information, providing a foundation which can be adapted and expanded upon as required.

i. Lead – Scottish Government

e. A published code of practice – respect for privacy and freedom of expression will be set out in a code of practice for addressing false health information (based on rapidly emerging international norms and frameworks) which emphasise that individuals must not be tracked or blamed for acting in good faith.

i. Lead – Scottish Government

f. Interventions are monitored and evaluated – the impact and effectiveness of efforts to protect health information integrity should be subject to monitoring and evaluation (M&E), with data collected and used to drive ongoing quality improvement. See page 36 for more detail on the proposed M&E approach.

i. Lead – Scottish Government

g. A coordinated approach across Scotland – development of the resources and infrastructure to address false health information at a national level should seek to coordinate and avoid duplication of effort. We will consider a ‘Once for Scotland’ approach where feasible, particularly for situations with national impact.

i. Leads – Scottish Government, Public Health Scotland

Pillar Two – Building Scotland’s Resilience to False Information

h. Principles

i. Implementation continues to contribute to the evidence base – the UK Online Media Literacy Strategy recognises a lack of robust evaluation to be a key limitation in media literacy interventions. This likely also extends into digital and health literacy. While research shows that promoting these literacies gives people protection against false health information, there remains a need to understand how best to tailor interventions to specific groups. This also includes ongoing work to better understand the impact of and intersectional link between digital, health and social inequality in Scotland.

i. Lead – academic partners involved in strategy implementation

ii. Existing work is supported – work underpinning this strategy should seek to link with and support existing media, digital and health literacy policy and programmes in Scotland while accounting for ongoing developments in research and on-the-ground evidence. This also includes grassroots and strategic work to address digital inequality.

i. Lead – Scottish Government

iii. Learning from other countries – countries with high levels of media literacy, such as Finland, can provide practical examples of effective and scalable interventions. Scotland should continue to seek to understand these countries’ experiences and identify learning which can be applied in our context.

i. Lead – Scottish Government

i. Education in schools – literacy skills are widely taught in schools, with programmes in development to support pupils to think critically about what they see and share online. Efforts to do this should be embedded across the Scottish Curriculum for Excellence, accounting for teacher and pupil views, with evaluation undertaken and published. Opportunities for subject specific input on health – such as around vaccination – should be maximised.

i. Lead – Education Scotland with support from Public Health Scotland

j. Trusted voices are supported and amplified – healthcare and community figures enjoy high levels of public trust. These figures may also often encounter situations influenced by false health information and should be supported and empowered to deal with these effectively and with compassion.

i. NHS staff are supported to gain the knowledge and skills to have evidence-based conversations with patients and to sensitively navigate situations that have been influenced by false health information – our engagement has indicated that healthcare staff find conversations influenced by false health information to be challenging. This is made all the more difficult by the complex psychological effects false information can have. In line with available resource, we will continue to develop evidence-based workforce education for use by staff to support these conversations.

i. Leads – Scottish Government, Public Health Scotland, NHS Education Scotland

ii. Healthcare staff and community figures are empowered to promote media, digital and health literacy – for conversations which are influenced by false information, the use of short interventions which empathetically explore media, digital and health literacy skills are likely to be of value. New methods for signposting the public to short and accessible tools which support these literacies will also be explored. This may take the form of links on vaccination invites, signposting at healthcare appointments or as part of other healthcare interactions where relevant. This should also include promotion in both easy read and community languages, informed by the insight of those communities. Existing workforce education should be strengthened and promoted through leadership networks. Additional online training to support health literacy promotion should be developed which is applicable to health, social care and other community contexts. Such interventions should be co-designed with patients and staff, address health inequalities and incorporate robust monitoring and evaluation.

i. Leads – Scottish Government and Public Health Scotland with support from third sector partners

iii. Health information bulletins to support clinical staff – to assist in patient interactions which are influenced by false information, we will explore the distribution of health information bulletins to clinical staff which provide factual information relevant to current false health information in circulation.

i. Lead – Public Health Scotland (specific to vaccination and immunisation)

k. False health information is accounted for in emergencies – developing and maintaining situational awareness is fundamental to the effective response to an incident. Those organisations and individuals who are involved in response should consider how best to ‘harden’ their processes and procedures to mitigate the risk of mis/disinformation corrupting situational awareness. Whilst the corroboration and veracity of information and information sources will already be considered by responders, actively codifying the mis/disinformation risk may help further support the resilience of response.

i. Lead – Scottish Government

Pillar Three – A Rapid Response Mechanism to False Health Information

l. A scalable emergency response – in times of crisis (e.g. pandemics), maintaining health information integrity becomes more challenging, with persistent uncertainty, rapid scientific development, and a high demand for good, timely information. Using existing assets, systems and processes wherever possible, our response to false health information will be developed and maintained by regular exercise and updates, ready to be scaled up when required.

i. Leads – Scottish Government, Public Health Scotland

m. Capabilities to rapidly assess the on- and offline information landscape for false health information – in line with existing guidance, emerging practice internationally and available resource, we will explore development of a system to understand circulating true and false health narratives, health information needs and concerns across Scotland. This system should be able to assess these narratives for risks to public health and provide recommendations for action. Insights from both online and offline spaces should be integrated where feasible, with community engagement as a core component. Other methods of assessing public concern, such as feedback from clinical networks, should also be explored. Outputs should be distributed in appropriate formats to professionals involved in health communication, healthcare provision and key partners.

i. Leads – Scottish Government, Public Health Scotland

n. False information is anticipated in advance – developments and events in health inevitably give rise to false information. An important method for tackling its effects is rapid and early communication, which is aided by sound forward planning. A rapid response mechanism to false health information should build in a horizon-scanning capability to anticipate such scenarios and plan for these in advance.

i. Leads – Scottish Government, Public Health Scotland

o. A false health information risk assessment framework is developed – not all false information can or should be addressed. A common risk assessment framework should be developed – integrating existing UK and international guidance – which sets out a process for assessing which false narratives are sufficiently widespread, harmful and impactful to public health to merit a response.

i. Lead – Scottish Government

p. A consistent communications response – clear guidance will be provided in the form of a toolkit to shape organisational response to false health information across the health and social care sector. We will make use of UK Government Communication Service best practice and international guidance. Use of this toolkit will help to support a coordinated, consistent, ethical and high-quality response across organisations. We will provide advice on channel and messenger choice to ensure information is effectively distributed in a changing media landscape.

i. Lead – Scottish Government

q. Seeking solutions to the harms of deepfakes – the resources to generate convincing audiovisual representations of public figures are readily accessible, low cost and require little specific expertise. These deepfakes threaten to undermine public trust in health messaging in times of crisis. Reliable solutions to mitigate this are yet to be identified and require ongoing work with partners across the UK and internationally.

i. Lead – Scottish Government

r. Methods to directly respond to false health information may be deployed in specific risk-assessed circumstances – where false narratives are assessed to be widespread, harmful and impactful to health, specific responses can be considered in line with existing UK and international guidance. Decisions to do this must be transparent, evidence-based and evaluated for impact.

i. Leads – Scottish Government, Public Health Scotland

Monitoring and evaluation

Key performance indicators will be developed as part of the implementation planning process, tailored to the areas and activities outlined in this strategy. Where applicable, these will be co-designed with delivery partners to ensure feasibility and alignment with their existing work.

A monitoring and evaluation framework will be developed during the early stages of implementation. This framework will outline how progress toward strategic objectives will be measured, how activities will be monitored and how learning will be captured and applied. This will form part of a quality improvement approach.

The framework will be designed in collaboration with delivery partners and informed by international best practice. It will include:

• high-level outcomes aligned with the strategy’s three pillars
• indicators for tracking impact over time
• provisions for monitoring impact on health inequalities
• a timeline and process for review

Progress will be reported annually, and the strategy will be formally reviewed in 2028 to assess effectiveness and determine next steps.