Coronavirus (COVID-19) business support: equality impact assessments

Mobile and Home Based Close Contact Services Fund

Name of Grant:

Mobile and Home Based Close Contact Services (MHBCCS) Fund

Policy Lead

Ewen Scott

Legal power used:

Section 126 of the Housing Grants, Construction and Regeneration Act 1996.

Grant Overview:

The MHBCCS Fund was launched to provide support to businesses impacted by Covid- 19, and to address gaps in UK Government support. The Fund was for owners and operators of mobile and home-based close contact service businesses and for registered driving instructors in Scotland. It was therefore specifically aimed at businesses such as beauticians, massage therapists, hairdressers/barbers, tattooists, services or procedures which require physical contact or close physical proximity between a provider and a customer and are not ancillary to medical, health, or social care services as defined in The Health Protection (Coronavirus) (Restrictions and Requirements) (Local Levels) (Scotland) Regulations 2020.^[54]

The Fund was operated on behalf of the Scottish Government by an external delivery organisation, UMi. Applications opened on 16 February 2021 for four weeks. The closing date was later extended by one week in response to stakeholder feedback. It closed to new applications on 23 March 2021, but processing continued until 30 April 2021. Applicants whose applications were in progress were permitted to submit further information as necessary to further support their applications. Partners most closely involved in the delivery of the Fund were:

• Scottish Government (SG) – the contract management team;
• Scottish Enterprise (SE) – the Find Business Support Helpline team;
• SLAED – the local authority liaison; and
• UMi - the contract delivery team.

Eligible applicants were able to apply and receive one payment of £4,000 from the MHBCCS Fund to alleviate financial hardship. The Fund has proved successful with 8,945 awards made totalling £35.8 million.

Executive Summary:

The Scottish Government considered from the start of the pandemic whether the lockdown provisions were consistent with the Equality Act 2010 and also considered whether the provisions could constitute indirect discrimination. In many cases, the provisions have applied to all persons irrespective of protected characteristic, although it is acknowledged that the same provision may not have equal impacts.

The Scottish Government understands the impact COVID-19 has had on businesses, which is why £4.4 billion has been provided to business support.

In order to address the needs of many sectors adversely impacted by the pandemic, a range of business support funds were introduced over several months to provide emergency funding to help secure jobs, safeguard businesses and to alleviate hardship.

Within this context, there has been limited opportunity to gather evidence on the possible impacts of these measures. However, given the importance of assessing the impact on each of the protected characteristics, the Scottish Government has considered the measures against the needs of the general equality duty as set out in section 149 of the Equality Act 2010 to eliminate unlawful discrimination, harassment and victimisation, advance equality of opportunity between people who share a protected characteristic and those who do not, and foster good relations between people who share a protected characteristic and those who do not. The Scottish Government has also considered whether the measures could constitute direct and/or indirect discrimination.

To align with the Strategic Framework, grants were awarded to Mobile Close Contact Service providers that resided in local authority areas that were subject to restrictions under Protection Level 2 or above and similarly provided grants to mobile hairdressers/barbers as well as driving instructors that were subject to restrictions under Protection Level 4. This was consistent with the approach adopted through the Strategic Framework Business Fund.

We are also mindful that the equality duty is not just about negating or mitigating negative impacts, as we also have a positive duty to promote equality. We have sought to do this through provisions contained in the measures or by support and guidance available.

Key Findings - impact assessment of benefits and/or disadvantages.

This emergency funding has supported otherwise strong and viable businesses, >protecting the business base, jobs and livelihoods of people across the range of protected characteristics, many of whom have been disproportionately affected by COVID-19.

There no specific data on characteristics and demographics for the driving instructors customer group. However, there is data for the more general group denoted as close contact service providers.

The closure of all close contact services will have impacted people of all characteristics - both those that deliver and those that use these services. We know that there is a disproportionate impact to women in close contact and mobile services sector 80.7% of close contact service providers are women.

This sector has been badly affected by the restrictions with many unable to earn an income between the first March 2020 lockdown and then at varying impacts (dependent on the regional location) upon the introduction of the level system in November 2020 and until level 2 restrictions were lifted depending on regional location from June 2021

Age: Older People and Children and Young People

19.1% of those working in close contact services are aged 16-24 compared to 12.3% of the workforce as a whole.^[55] As the proportion of young people who work in close contact services is higher than the total workforce average, young people working in this sector may have been more likely to be economically disadvantaged as a result of the restrictions. No data is available in relation to the age of those applying for support from this fund.

Sex: Men and Women

Hairdressing and hair removal services and beauty services, including make-up, tanning and nail treatments accounted for 46% of the applications received for this fund. Women are significantly more likely than men to work in the ‘other personal service activities’ sector (referred to as “Close Contact Services” in this document). No such data is available for driving instructors.

Women made up 80.7% of the total close contact services workforce in 2019.^[56] The closure of certain mobile close contact services is therefore likely to potentially have had a negative impact disproportionately on females and income. However, eligible self–employed female applicants would have benefitted from the funding available. While there is no reliable data on how many women use these services, the high proportion of women working in the sector may correlate to a similarly high number of women users of the services.

Men make up less than 20% of the mobile close contact services workforce and a third (33.8%) of the workforce of close contact services more generally is self-employed, higher than the Scottish average of 12.4%.^[57] While the proportion of men impacted by closure of mobile or close contact services was likely to be less than that of women, the economic impact in terms of loss of income is likely to be similar to women.

The National Hair and Beauty Federation Industry Data booklet 2019 reports a 64% increase in the number of barber shops across the UK over a 5 year period (2014-2019). Barbering businesses will be among those captured in the Scottish Government’s Monthly GDP statistics for August 2020^[58] that shows the close contact services sector as 34.2% lower in August compared to the same period in August 2019 and 10.0% lower for the economy overall.

As barbering services are almost exclusively used by men they are likely to have been impacted by their closure, but no more or less so than other groups with protected characteristics..

Race

There are an estimated 30,000 people employed in the close contact services workforce of which 6.7% are from an ethnic minority. 90.9% of the close contact services workforce is a UK National, 4.7% an EU National, and 4.4% is an Other Non-EU National.^[59] As 9% of those delivering these services are non-UK nationals the impact of closure of such services would be greatest among those who class themselves as UK nationals. More generally, at a UK level, In 2019 the overall self-employment rate for minority ethnic adults (16.1%) was higher than for the 'White' ethnic group (12.2%).

Disability

There is no data available to establish the number of disabled people that either work in personal close contact services or are users of such services. However data suggest that 9% of SMEs employing sole traders registered as having a disability.

Where mental health is the disability, there is the potential that ceasing mobile close contact services may have exacerbated any underlying mental health issue.

Additionally, it is notable that disabled people may rely on close contact services to help maintain quality of life, and on mobile services if they are unable to easily leave the home. Restricted access to such services could potentially reduce quality of life. For disabled people who receive either physical, or therapeutic relief from such services, their closure might have had a detrimental impact on physical wellbeing.

Religion and Belief

There is no evidence of a differential impact identified at this time.

Sexual Orientation

There is no evidence of a differential impact identified at this time.

Pregnancy and maternity

There is no evidence of a differential impact identified at this time.

Gender reassignment

There is no evidence of a differential impact identified at this time.

Marriage or Civil Partnership

There is no evidence of a differential impact identified at this time.

Socio-economic disadvantage: any people experiencing poverty

Socio-economic impacts may have potentially been experienced predominantly by women between the first March 2020 lockdown and then at varying impacts upon the introduction of the level system in November 2020 until level 2 restrictions were lifted depending on regional location from June 2021.

The National Hair and Beauty Federation Industry Data booklet 2019 reports the average annual salary of hairdressers and barbers was £17,609 and the average annual salary of beauticians of £17,178.

Whilst not representative of all services provided under the broader close contact services categorisation, these salaries fare significantly lower than the weekly rate of £428.80 which is the Median Gross Weekly Public Sector Earnings for Scotland in 2018.^[60]

The Scottish Government’s Monthly GDP statistics for August 2020^[61] shows the close contact services sector as 34.2% lower compared to August 2019 and 10.0% lower for the economy overall.

A third (33.8%) of the workforce of the close contact services sector are self-employed, higher than the Scottish average of 12.4%.^[62] Closure of mobile close contact services will have a higher than average impact on those that are self-employed, who may already be economically disadvantaged through low levels of pay. The take-up rate of the UK Government’s Self-Employment Income Support Scheme (SEISS) for the other service activities sector in Scotland was 78% as at 30 September.

As previously stated, the Scottish Government’s Monthly GDP statistics for August 2020 shows a year on year contraction of the close contact services sector between 2019 and 2020 (34.2% lower in August compared to August 2019) and 10.0% lower for the economy overall. Closure of mobile and home based close contact services impacted a sector which is predominantly used by and employing women.

Stakeholder Engagement:

The Scottish Government has engaged extensively with businesses and their representative organisations since March 2020 and has regular meaningful engagement with business leaders on a range of priority issues, including economic recovery and business support. During the 16 month period from March 2020 to July 2021 over 1,270 engagements took place, and a regular programme of engagement continues, including with CBI, FSB, IoD, Scottish Chambers of Commerce, SCDI, Scottish Financial Enterprise, Scottish Retail Consortium, Scottish Tourism Alliance and Scotland Food and Drink.

Prior to the launch of this Fund, and regularly thereafter, Scottish Government officials engaged regularly with the following business or stakeholder bodies:

• Association of Driving Instructors;
• Approved Driving Instructors National Joint Council (ADINJC);
• Beauty Booker;
• The British Association of Beauty Therapy and Cosmetology (BABTAC);
• Salon Logic;
• Excluded UK; and
• Scottish Massage Therapists Organisation

This provided an opportunity to listen to stakeholder views, test ideas, share information about progress and discuss and address specific issues identified by sectors and individual businesses.

Daily project management meetings were also initiated before the go-live date and held throughout most of the delivery period between UMi, SG and broader partnership representatives including SLAED and Scottish Enterprise (SE). Changes to the service specification were discussed and agreed at these meetings in response to stakeholder feedback, applicant experience and internal risk management strategies.

Management information on the Fund continues to be published on the Scottish Government website.^[63]

Mitigations –

A fully assisted application process was put in place, whereby an UMi assessor could take the details and submit an application on behalf of an applicant if they were unable to complete an application themselves. This solution was built to assist any prospective applicant that wished to utilise it, including those user groups that may have visual/disability challenges in being able to apply online to the fund.

An appeals process was introduced to ensure that there were sufficient routes to challenge decisions and have applications reviewed by a separate team. This was undertaken by the Scottish Government’s Covid Income Support Team. A one to one telephone service was introduced to help applicants discuss their application with an assessor.

Dedicated mailboxes were established to handle the large volume of enquiries from applicants, MSPs, MPs and other stakeholders to enhance accessibility. These mailboxes received over 1,000 enquiries. The mailboxes continued to be monitored after the fund closed with an automatic message signposting an alternative means of Scottish Government contact. A phone helpline was also set up by SE to aid the application process. This helped negate some accessibility issues and provided applicants a chance to speak to someone directly about any issues or problems they were having with applying for funding.

The Scottish Government recognised that there were a wide range of businesses impacted by restrictions in this category who did not meet the eligibility criteria for the Wedding Industry Fund, and as such who were not eligible for financial support through this fund.

The Scottish Government set up a number of other grant support schemes for the purposes of ensuring that those experiencing financial hardship, as a result of Covid-19 received appropriate support. This included, but not limited to; the Strategic Framework Business Fund, specific schemes for taxi and private hire vehicle drivers, accommodation providers, as well as the Local Authority Discretionary Fund which identified businesses that operated from closed or restricted sectors, those that rely on entering domestic premises and those in the supply chain of closed or restricted sectors as types of business that local authorities should consider supporting.

Next Steps (if any)

Where any unintended negative impacts have been identified, we will seek to mitigate/eliminate these by setting out areas which should be subject to further consideration during the development of possible future business support funds. The findings of this EQIA will help to aid the design and introduction of possible future schemes, should resources become available.

Declaration and Publication

I have read the Equality Impact Assessment and I am satisfied that it represents a fair and reasonable view of the expected equality impact of the measures implemented.

Signed:

Date: 08/11/2021