Coalition for Racial Equality and Rights - anti-racist policy making: review

Gathering evidence

Over time, race equality strategy in Scotland has varied in its approach to evidence based policy. Some strategies have been relatively light on evidence, instead primarily seeking to address Scottish Government's ethos on race equality and relying on actions that embed that ethos into the priority areas of the time. Others have been built from a robust evidence base that clearly specifies the nature of the racial inequalities Scottish Government aims to tackle.

A good evidence base is the foundation of effective race equality work. It doesn't guarantee that a strategy will be effective – the design of actions and their implementation can still falter. However, it isn't possible to set the right actions without understanding what they need to accomplish.

Policy makers undoubtedly work with an awareness of the need for evidence, and the range available from internal and external sources (for example primary and secondary research, monitoring data, and staff, service user and stakeholder involvement). Securing the necessary staff time for the gathering and analysis of this evidence, however, can be difficult.

In some of the mid-period strategies examined, the patchy approach to evidence suggests that this may have been 'retrofitted' to suit the commitments made (suggesting that perhaps, not enough time was available to set out the evidence and use it to generate commitments).

This mid-period is bookended by strategies with a clearer focus on evidence. In both cases, the involvement of stakeholders outside Government in gathering and presenting this evidence was key.

The Race Equality Advisory Forum (REAF), an external stakeholder group set up to support Scottish Government's work on tackling institutional racism, set out a full report on racial inequality in Scotland in 2001. This made a series of recommendations, complemented by eight plans covering specific sectors. Whilst the REAF recommendations could have achieved more, the impact of the evidence it presented could be seen throughout policy on race equality over the next few years.

A large amount of additional evidence was generated over this time. Partly as a result of the REAF recommendations, the Scottish Executive made a considerable investment in conducting social research with a focus on race equality.

The Race Equality Framework for Scotland 2016-2030 returned to this focus on evidence based policy, and although a light touch approach within the document itself sets out only the headline information for context, an accompanying set of research reports and findings^[155] from extensive stakeholder engagement ensured that policy makers had a strong understanding of the issues.

Stakeholder engagement was extensive and took different approaches for practitioners (around 300 participating in Strategic Action Forums) and community members (around 400 participating in peer-led focus groups through the Community Ambassadors Programme). Crucially, during the policy development process, views gathered through these two different programmes were compared with evidence from primary and secondary research to reach a holistic understanding of the action needed.

This comparison was needed in order to gain an accurate view of the evidence. Statistical evidence misses out the nuance of personal and professional experience, whilst personal and professional experience is subjective and can be skewed by misinformation and misunderstanding.^[156] For this reason, in both stakeholder involvement mechanisms, a group had to agree fully on the feedback to be submitted. Where there was disagreement, this could be noted separately. This aided with prioritisation of the most widespread and entrenched issues.

The work undertaken was successful in building a strong evidence base precisely because it was extensive and time consuming. However, a running programme of work (like that recommended by the Expert Reference Group on Covid-19 and Ethnicity)^[157] could have avoided the need for concentrated effort of this kind.

As no running programme of evidence gathering on race equality was in place, constraints of internal capacity within Scottish Government to undertake this work were mitigated by bringing CRER into the policy making process to provide support and manage the process of community engagement.

This evidence base remains relevant, and as well as informing Scottish Government policy, the publication of the range of reports means that policy makers in other parts of the public sector, as well as academics, activists and campaigners, can draw on it within their own work. Continuity of availability of research and involvement evidence is important to avoid 'reinventing the wheel' and creating consultation fatigue amongst those who take part in involvement.

Building a strong evidence base can also be hampered by the availability of appropriate data disaggregated by ethnicity. A number of recent reports have highlighted continuing difficulties with data gaps.^[158]

Some data gaps recur consistently over time; for example the aforementioned need to link ethnicity to CHI records in the healthcare system to allow disaggregation of data by ethnicity.^[159] As mentioned previously, by 2020, the issue was raised again in the work of the Expert Reference Group on Covid-19 and Ethnicity. Creation of a CHI ethnicity field was the third recommendation of its report on improving data and evidence.^[160]

Other data gaps appear over time, as systems change and certain information is no longer produced (for instance, free school meals data disaggregated by ethnicity).

It's important to note, however, that the main aspects of racial inequality are all well-evidenced already. As vital as widening the evidence base is, there can be a temptation to focus solely on gathering more evidence, at the expense of taking action.

Further evidence can help to make action more focussed, but where enough exists to demonstrate an inequality, it should be used accordingly to create action. Published commitments to seek more evidence or to further consider the available evidence are not always implemented, and rarely lead to eventual action.

Knowledge and capacity to access the data available may also be an issue for policy makers, especially those seeking to mainstream race equality into their own policy area. Whilst the Equality Evidence Strategy and Equality Evidence Finder have made a start at addressing this, there are opportunities to improve access to data. In the 2017 Equality Outcomes and Mainstreaming Report, staff survey results showed that only 28% of staff were aware of Equality Evidence Finder, compared to 60% aware of Equality Impact Assessment (EQIA) tool and guidance.^[161]

To strengthen the focus on evidence based policy on race equality, Scottish Government may want to consider:

• Renewing the Equality Evidence Strategy when it comes to its end in 2021, informed by a full review of the availability of ethnicity disaggregated data, how this is presented within Equality Evidence Finder and how use of both data and evidence from involvement can be maximised in policy making
• Implementing the data and evidence related recommendations of the Expert Reference Group on Covid-19 and Ethnicity, and considering the implications of these for data beyond health policy where relevant
• Working to improve coverage of ethnicity disaggregated data in relation to the National Performance Framework^[162]
• Capacity building activities for policy makers on collating and using ethnicity evidence
• Ensuring that revisions to data collection and publication processes are subject to Equality Impact Assessment in order to avoid creating future data gaps
• Working with stakeholders to improve the coherence, consistency and sustainability of mechanisms for gathering evidence from those with lived experience of racism (e.g. involving minority ethnic community members and minority ethnic led organisations)

The use of Equality Impact Assessment is outwith the remit of this review, however this is vital for mainstreaming race equality in areas which are not linked to specific race equality strategies (or for areas where race equality strategies simply state that race equality will be 'considered'; a large volume of commitments of this nature were identified during the review). Race equality strategies themselves should be subject to Equality Impact Assessment, with work on this beginning at evidence gathering stage.

There may be opportunities for greater synergy between evidence gathering for Equality Impact Assessment processes and for race equality strategic purposes.