Culture strategy for Scotland consultation: analysis of responses - full report

Impact assessments

The consultation paper notes that the draft strategy has been pre-screened as having no or minimal effects on the environment and the relevant information has been submitted to the Consultation Authorities as part of the statutory Strategic Environmental Assessment process. Partial assessments have also been carried out to consider how the draft strategy may impact on equality, the rights and welfare of children, business (including third sector) and regulation.

Question 18: Do you think the partial Equality Impact Assessment has identified where the strategy might impact on people differently depending on characteristics such as age, disability, gender, race, religion or belief, sexual orientation or gender identity?

Question 19: If you have further comments on the Equality Impact Assessment, please provide them below.

Table 7: Question 18 – Do you think the partial Equality Impact Assessment has identified where the strategy might impact on people differently depending on characteristics such as age, disability, gender, race, religion or belief, sexual orientation or gender identity?

	Yes	No	Don't know	Not answered	Total
Organisations:
Academics, University, Higher Education or Further Education	5		1		6
Culture (arts, cultural heritage, creative industries) organisation, group or company	15	3	17	11	46
Faith Group				2	2
Local Authority or Culture Trust	8	1	3	4	16
National Collections and Performing Companies	2		4	3	9
Public Body	5	1		5	11
Representative or umbrella group	11	1	11	11	34
Third sector	4	1	5	6	16
Union or political party	3		1	2	6
Total organisations	53	7	42	44	146
% of organisations answering	52%	7%	41%
Individuals	25	5	30	9	69
Individual (on behalf of a community)			1		1
Total Individuals	25	5	31	9	70
% of individuals answering	41%	8%	51%
All respondents	78	12	73	53	216
% of all respondents	36%	6%	34%	25%
% of all those answering	48%	7%	45%

* if figures do not sum to 100% this is due to rounding.

Opinion was mixed as to whether the partial Equality Impact Assessment has identified where the draft strategy might impact on people differently depending on characteristics such as age, disability, gender, race, religion or belief, sexual orientation or gender identity. The largest proportion of respondents – 48% of those answering the question – thought it had. However, 45% of those answering the question did not know.

Relatively few respondents went on to make a further comment and each of the issues set out below were raised by one or a small number of respondents.

Points made by respondents who thought the partial Equality Impact Assessment had identified where the draft strategy might impact on people differently included that it appears evidence based and fair.

There was a view that throughout the draft strategy, the term 'diversity' is used both in relation to ethnic diversity and in relation to overall diversity of cultural output or activity. This was seen as unhelpful and as risking conflating these concepts. It was suggested that the term 'race equality' or 'representation of minority ethnic individuals and communities' be used instead of diversity in the context of race equality.

Further comments included that it will be important for young people and children to have an input and also that it is very important that efforts are made to open up opportunities for a dialogue so that disabled people, including artists, are actively engaged in discussions. Other suggestions included:

• a Human Rights and Equality Integrated Impact Assessment should be carried out.
• a more detailed Equality Impact Assessment will be required once the draft strategy has been developed further.
• it is important to recognise the different cultures and heritages of children and young people. This is particularly important when, for example, there are only a very small number of children in a school who share the same heritage.
• rural inequalities and the barriers of rural disadvantage to participation are under-recognised.
• the protection of the rights and economic independence of freelance workers and writers could be tied in with the Equality Impact Assessment.
• options from elsewhere which offer interesting models for engaging people, such as those in prison, should be considered.
• the work in progress from Glasgow Women's Library on equalities could be included in the draft culture strategy as an example of best practice in this area.

Other comments included that it is not clear why the organisations selected to comment on the partial Equality Impact Assessment in advance of the full consultation were chosen. It was noted that these organisations (set out in Annex A of the Partial Equality Impact Assessment document) do not include any with an interest in dyslexia and this was seen as an omission.

Those who did not know or did not think the partial Equality Impact Assessment has identified where the draft strategy might impact on people differently suggested that insufficient information has been made available to make an assessment. Other comments included that:

• the Equality Impact Assessment refers to analysis of the arts, however this does not cover the breadth of the sectors represented by the draft Culture Strategy.
• the impact upon linguistic minorities, including British Sign Language users, must be noted.
• there is no reference to the Gypsy Traveller community.
• the Lesbian, Gay, Bisexual and Transgender reference should perhaps be to the Lesbian, Gay, Bisexual, Transgender and Queer community.

Other suggested omissions included reference to the lack of equalities awareness in the culture sector and the impact this has. It was also noted that there is no mention of adult and community learning despite this being how most disadvantaged communities will encounter culture and creativity.

Finally, the Equality Impact Assessment's conclusion that there would be no differential impact on protected characteristic groups and that everyone would benefit was questioned. It was suggested that there was not enough detail and that the final Equality Impact Assessment should have sections specific to each protected characteristic group, examine available evidence, highlight evidence gaps, and recommend actions that should be taken to ensure all groups – especially those that are disadvantaged – are able to benefit from the draft strategy.

Question 20: Do you think the partial Children's Rights and Welfare Impact Assessment sets out how the proposals presented in the strategy might impact on the rights and welfare of children?

Question 21: If you have further comments on the Children's Rights and Welfare Impact Assessment, please provide them below. For example, what would you add or change?

Table 8: Question 20 – Do you think the partial Children's Rights and Welfare Impact Assessment sets out how the proposals presented in the strategy might impact on the rights and welfare of children?

	Yes	No	Don't know	Not answered	Total
Organisations:
Academics, University, Higher Education or Further Education	5		1		6
Culture (arts, cultural heritage, creative industries) organisation, group or company	11	3	20	12	46
Faith Group				2	2
Local Authority or Culture Trust	8	2	2	4	16
National Collections and Performing Companies	2		4	3	9
Public Body	5		1	5	11
Representative or umbrella group	6		16	12	34
Third sector	4		7	5	16
Union or political party	3		1	2	6
Total organisations	44	5	52	45	146
% of organisations answering	44%	5%	51%
Individuals	25	4	30	10	69
Individual (on behalf of a community)			1		1
Total Individuals	25	4	31	10	70
% of individuals answering	42%	7%	52%*
All respondents	69	9	83	55	216
% of all respondents	32%	4%	38%	25%
% of all those answering	43%	6%	52%

* if figures do not sum to 100% this is due to rounding.

Opinion was again mixed as to whether the partial Children's Rights and Welfare Impact Assessment sets out how the proposals presented in the draft strategy might impact on the rights and welfare of children. A small majority of respondents – 52% of those answering the question – did not know, while 43% of those answering thought it did and 6% of those answering thought it did not.

All of the issues set out below were raised by only one or a small number of respondents.

Comments by those who 'did not know' included that there is very little information about how the draft strategy might actively promote children's rights and welfare, for example through early years cultural provision and cultural activities which support life skills, confidence and wider achievement as well as supporting attainment.

Other comments included that:

• greater consideration of barriers to participation and access to cultural activities – including, equal access for children and young people to education in the arts and culture – would be welcome.
• it is important to consider deaf children whose home circumstances do not readily offer them access to British Sign Language.

It was suggested that there should be a stronger requirement on local authorities to support, deliver and measure culture, including because their support through education and community work is key. It was also suggested that the draft strategy itself requires more explicit acknowledgement of, and reference to, the early years.

Those who thought the assessment does set out how the proposals presented in the draft strategy might impact on the rights and welfare of children sometimes noted that all children should have easy and early access to a range of culture or that access to a range of culture through education, both formal and informal, is a basic right. They also suggested additions to the Assessment, including:

• it should mention deaf children and British Sign Language to make sure that they receive the support required on an equal basis with others.
• the importance of museums for children should be included.

In terms of changes to the draft strategy itself it was suggested that it should refer to the United Nations Convention on the Rights of the Child and include the Safe, Healthy, Achieving, Nurtured, Active, Respected, Responsible and Included indicators in the draft strategy.

It was also noted that there is a lack of data about the impact of culture and creativity on specific groups of children and young people, and that this will need to be addressed by the Measuring Change Group.

Those who did not think the assessment sets out how the proposals presented in the draft strategy might impact on the rights and welfare of children suggested it is lacking in detail, incomplete or inconclusive. Specific elements identified as missing included:

• how the delivery of the draft strategy will impact areas such as the Curriculum for Excellence, the National Improvement Framework and community learning and development.
• clear and detailed actions to support safe cultural activity relating directly to, or in support of, the rights and welfare of children.

It was also suggested that final assessment should draw on all available evidence, such as the 2008 Scottish Government report on Children's Participation in Culture and Sport, in assessing the final strategy's aims and actions.

Question 22: How do you think this strategy might impact upon people on low incomes, people living in deprived areas, people in material deprivation, people with no / or low wealth and people from different socio-economic backgrounds? Please provide comments below.

Many respondents identified positive or potentially positive impacts for the groups of people listed, although sometimes noting that their expectation is based on successful implementation of the draft strategy.

Among specific outcomes suggested were:

• greater access to or engagement in cultural activities. This was the most frequently identified outcome.
• greater visibility of the cultures of people in the groups listed.
• a cultural sector that reflects wider society.
• other economic and social benefits.

However, it was also suggested that there may be little or, potentially, no impact at least initially, and that long-term support and engagement will be required to deliver potential benefits. The difficulties in engaging with disadvantaged groups were also noted with a suggestion that change will take a long time. The need for more specific targets or tangible actions and regional priorities to reflect local factors were suggested for the draft strategy.

The difficulties in evaluating such impacts were also suggested, and the need to develop an appropriate evidence base was highlighted.

Amongst the actions identified as necessary for positive impacts to be realised were to:

• listen to the views of the people in these communities and address issues of cultural confidence. This was the most frequently identified action.
• commit to more co-production.
• embed cultural activities in education.
• let people know what is available.
• provide adequate resources and, potentially, reallocate resources within the culture budget or to less affluent areas.
• overcome barriers to participation, including both financial and transport.
• write the draft strategy in an accessible way using imagery rather than too much text.

Greater involvement for local authorities and the voluntary sector was also proposed, with a suggestion that these are under-represented in the draft strategy. Providing opportunities for third sector bodies to be involved in procurement of cultural programmes was suggested to have potential to bring future investment, while it was also argued that funding processes should be modified to make it easier for disadvantaged groups to apply.

Risks identified as having the potential to prevent benefits from being realised included a lack of buy-in from experienced cultural actors and a perceived gap between 'custodians of culture' and the wider population.

Only a small number of respondents argued that the draft strategy might have negative impacts for the groups listed, including by wasting money or taking money from education and health budgets, or by being expected to participate in 'other people's culture'.

Question 23: Do you think the partial Business and Regulatory Impact Assessment identifies how the proposals presented in the Strategy might impact on businesses, the third (voluntary) sector or have any regulatory impact?

Question 24: If you have further comments on the Business and Regulatory Impact Assessment, please provide them below. For example, what would you add or change?

Table 9: Question 23 – Do you think the partial Business and Regulatory Impact Assessment identifies how the proposals presented in the Strategy might impact on businesses, the third (voluntary) sector or have any regulatory impact?

	Yes	No	Don't know	Not answered	Total
Organisations:
Academics, University, Higher Education or Further Education	5		1		6
Culture (arts, cultural heritage, creative industries) organisation, group or company	9	2	21	14	46
Faith Group				2	2
Local Authority or Culture Trust	7		5	4	16
National Collections and Performing Companies	1		5	3	9
Public Body	4	1	1	5	11
Representative or umbrella group	2		19	13	34
Third sector	3	1	7	5	16
Union or political party	2		2	2	6
Total organisations	33	4	61	48	146
% of organisations answering	34%	4%	62%
Individuals	21	6	31	11	69
Individual (on behalf of a community)			1		1
Total Individuals	21	6	32	11	70
% of individuals answering	36%	10%	54%
All respondents	54	10	93	59	216
% of all respondents	25%	5%	43%	27%
% of all those answering	34%	6%	60%

* if figures do not sum to 100% this is due to rounding.

A majority of respondents – 60% of those answering the question – did not know if the partial Business and Regulatory Impact Assessment identifies how the proposals presented in the draft strategy might impact on businesses, the third (voluntary) sector or have any regulatory impact. Of the remaining respondents, 34% of those answering thought it did and the remaining 6% of those answering thought it did not.

Only a small number of respondents went on to make a further comment, with those comments tending to be brief. Each issue set out below was raised by only one respondent.

Comments often focused on the impact the draft strategy will have and included that:

• the greater recognition of the contribution and role of the voluntary sector in cultural provision and opportunities will impact greatly on that sector.
• cultural businesses should benefit from the validation of their contribution to the country, including economically and socially.
• there needs to be a balance between commercial and social value.
• the draft strategy lacks sufficient clear and specific, measurable, achievable, relevant and time-bound detail to determine how it might impact on businesses, the third sector or have any regulatory impact.

A query raised was whether it is appropriate to have a single assessment that covers both the private and third sectors. It was also noted that the majority of care services in Scotland are delivered by the 'independent sector' and it was suggested that reference to the third sector is not sufficiently inclusive.

There was also a comment that the assessment that the draft strategy does not impose any additional burdens or duties on the sector may not be correct if:

• increased reporting and evaluation are expected.
• funding is targeted too much into particular areas of short-term activity rather than recognising the long-term need for maintenance of cultural assets such as museum collections.

It was also suggested that the delivery of the actions and any programmes or initiatives could impact on businesses operating in the cultural sector. For example, that procurement processes are often barriers to successful engagement with small community-based groups and do not recognise the core funding requirements of smaller organisations.

Other issues identified included that:

• addressing the varying needs across businesses and services in different sectors is significantly challenging.
• encouraging enterprise and growth of new business-to-business arrangements would be welcome.
• there is no mention of how the enterprise network, including Scottish Enterprise, might work with cultural and heritage organisations to realise social, economic and environmental impacts.
• there is no recognition of the financial challenges small culture-based businesses face, for example in relation to rent and business rates.

In conclusion

This report has presented a detailed analysis of responses to the Scottish Government's consultation on a draft "A Culture Strategy for Scotland". A broad range of respondents made submissions, often providing detailed further comments. At the closed questions, there were consistently high levels of support for the vision, ambitions and actions set out. Respondents often went on to make suggestions about how the draft strategy could be further developed, sometimes noting their own interest in being involved in both that development process and the delivery of the final "A Culture Strategy for Scotland".