Consultation on Restricting Alcohol Advertising and Promotion: Analysis of responses

15 Equality issues (Q42)

15.1 The final section in the consultation paper noted the Scottish Government's commitment to equality and ensuring that policies lead to the creation of a fairer Scotland. Question 42 asked respondents for their views on equality issues relevant to the introduction of restrictions on alcohol marketing.

Question 42: Are there any relevant equality issues that Scottish Government should be considering at this stage in the policy development?

15.2 Just over half of all respondents commented at Question 42. (This includes some who simply said they had no comments.) Comments were offered by organisations of all types and by individuals. As with other questions, organisations were more likely to give more detailed answers while individuals generally provided brief comments only. Many respondents used this question to repeat points made at other questions about their overall views on possible restrictions on alcohol marketing. Such points are not covered here.

15.3 Among those who broadly supported the introduction of restrictions on alcohol marketing, there was a consensus that the issue of equalities was highly relevant and should be prioritised in the policy development process.

15.4 In general, this group agreed that 'alcohol harm is not equally experienced in Scottish society' and highlighted socio-economic inequality as a key issue. They provided statistics to illustrate the higher rates of alcohol-related ill-health and mortality in areas of high deprivation and went on to argue that any steps to reduce alcohol consumption would bring the greatest benefits to the most disadvantaged groups in society.

15.5 Some respondents in this group also commented on other equality-related issues, mainly related to children and young people; women; people with disabilities and health issues; and the LGBTQ+ community. These were all identified as groups who would benefit from further restrictions on alcohol marketing. Issues pertaining to children and young people were frequently commented on at Question 35 and in the responses to other questions in the consultation, while other issues were raised by relatively small numbers of respondents. The comments made are summarised below:

• Children and young people: Respondents frequently highlighted the exposure and susceptibility of children and young people to alcohol marketing, and the links to harmful drinking behaviours. They frequently said that action should be taken to minimise children and young people's exposure to alcohol marketing and reduce the risk of harmful drinking in later life. Children were also noted as the victims of alcohol-related harm in terms of experiencing domestic violence and family breakdown.
• Women: Respondents noted three main points: (i) that women were being increasingly targeted by alcohol marketing, (ii) that women's health was often impacted by alcohol and (iii) that women were particularly susceptible to alcohol-related harm as victims of alcohol-fuelled domestic abuse.
• People with disabilities and health issues: Respondents noted a range of issues related to disability and both physical and mental health. As noted above, respondents often highlighted the prevalence of alcohol-related ill-health in Scotland, particularly among those in poorer communities. They also highlighted that alcohol consumption can cause mental health conditions and is more common among those with mental health conditions. Other points noted by small numbers of respondents were (i) that it was important to tackle harmful drinking to reduce the prevalence of foetal alcohol syndrome in babies born to mothers who consume high levels of alcohol during pregnancy, (ii) that those with cognitive impairments, those with conditions such as ADD and ADHD, and those with addictions can be prone to impulsive behaviour and may be more susceptible to alcohol marketing, and (iii) that alcohol consumption can be a particular risk for people (often older people) taking medication for a health conditions.
• LGBTQ+ community: Respondents said that harmful drinking was particularly prevalent among LGBTQ+ people. They highlighted the high levels of exposure to alcohol and alcohol marketing due to the importance that bars and pubs have in LGBTQ+ communities.

15.6 Occasionally respondents also mentioned (i) the link between alcohol consumption and other risky and harmful behaviours; (ii) the need to consider the climate change and carbon-emission implications of the alcohol industry; and (iii) possible consequences if Scotland and other Western countries became less attractive markets, and alcohol producers shifted the focus of their marketing efforts to developing countries, which could lead to increased consumption and harm in such countries.

15.7 In addition, some respondents highlighted:

• The need for action to address the causes of alcohol harm – which are rooted in poverty and social inequality. Some highlighted the need for a whole system approach in the policy process which also tackled the influence of big corporations – the WHO's Framework Convention on Tobacco Control was noted as a model in this area.
• The importance of viewing the issue through a children's rights and human rights lens.

15.8 Going forward, respondents saw the following as important to policy development and success:

• Collecting equality data at local authority and health board levels to understand the differential effects of alcohol consumption and harm for different groups and to monitor the impacts of any policy interventions
• Conducting an equality impact assessment, a children's rights impact assessment, and a Fairer Scotland Duty assessment
• Engaging with children and young people and other equality groups, and those affected by or in recovery from harmful drinking.

15.9 Among organisations and individuals broadly opposed to introducing restrictions on alcohol marketing, comments often focused on the perceived negative impacts the proposed measures would have on the alcohol industry and related businesses, and communities, particularly with regard to rural areas. These impacts have been discussed in some detail in the previous chapter and are not repeated here.

15.10 While much of the focus of the comments from this group was on the potential impacts on small businesses and people in rural areas, respondents also highlighted the important and positive role of bigger companies (drinks producers and retailers) in providing good quality employment in urban and often disadvantaged areas.

15.11 Occasionally, respondents in this group made specific points about the potential impacts on particular equality groups. These included the following:

• Respondents in the events and sporting sectors highlighted the impact that loss of sponsorship and advertising revenue would have on events and organisations of all types including (i) community events in rural areas reliant on the alcohol industry, (ii) the festival and events sector which was particularly important to young people and (iii) sports and physical activity opportunities for different equality groups such as young people, those with disabilities, those from the LGBTQ+ communities.
• Respondents in the hospitality and retail sectors highlighted the impact of potential price rises on consumers, and the impact of potential shop closures in local areas on consumer choice, particularly for those without access to a car. Some also pointed out the potential impact on minority ethnic groups, given the high proportion of convenience stores owned and run by members of Scotland's Asian community.

15.12 Some respondents in this group recognised that alcohol harm is experienced unequally across society but said that this should be addressed by tackling poverty and inequality, by providing improved public health education and treatment and recovery services, and by changing Scotland's drinking culture. Some also said that policy interventions in this area should be targeted at affected communities or groups, rather than being based on a whole population approach, as would be the case with the marketing restrictions proposed in the consultation.

15.13 Finally, around a quarter of respondents said that they did not see any equality issues related to the issues under consultation, often simply answering 'no' or 'none', or saying that equalities were not relevant to the matter under consideration. It was also relatively common for individuals in particular to say that they did not understand the question.