Health Protection (Coronavirus) (International Travel) (Scotland) Regulations 2020: Equality Impact Assessment

Race

Analysis by National Records of Scotland (NRS) has found that deaths among people in the South Asian ethnic group were almost two times as likely to involve Covid-19, compared to deaths in the White ethnic group (after accounting for age group, sex, area-level deprivation and urban rural classification). NRS note they do not have sufficient evidence to say that deaths among people in the Chinese ethnic group were more likely to involve Covid-19, and due to the low number of completed records for deaths involving Covid-19 in other minority ethnic groups, NRS also stated they were not able to carry out analysis of the relative likelihood that deaths involved Covid-19^[66]. Analysis from Public Health England in June showed that death rates from Covid-19 were highest among people in the Black and Asian ethnic groups^[67].

Measures that may help limit the spread of coronavirus are designed to positively affect the entire population, but may particularly benefit people in the South Asian ethnic group.

Scotland’s 2011 census found that the 'White: Polish' ethnic group had the highest rate of overcrowded households (30 per cent), followed by 'Bangladeshi' and 'African' households (both 28 per cent). This compares with 8% for ‘White: Scottish’ and 6% for ‘White: Other British’^[68]. Furthermore, the report by Public Health England noted that Black, Asian and Minority Ethnic people may be at an increased risk of acquiring coronavirus due to factors such as overcrowded households^[69].

While the measures are designed to limit the further spread of coronavirus, a returning traveller required to self-isolate, and living in an overcrowded household, may find it more difficult to distance themselves from other members of their household. This may potentially contribute to an increased risk of the spread of the virus within such a household, and this may be particularly pertinent among people from minority ethnic groups (including among the South Asian ethnic group).

The UK Government can provide accommodation for those who cannot self-isolate safely in their own accommodation. Furthermore, a new expert group will work with the Scottish Government to provide a clearer picture of the impact on minority ethnic communities of coronavirus. The group will consider evidence and data being gathered by the Scottish Government, Public Health Scotland, National Records of Scotland and the NHS, and advise on policy actions to mitigate any disproportionate effects^[70].

The Scottish Government will continue to take into consideration any newly identified evidence, in relation to any impacts the requirement to self-isolate for 14 days may have on minority ethnic people, and use this evidence to make changes, as appropriate.

Ready Scotland’s additional support page^[71] links to support and guidance for anyone struggling with their mental health and well-being, provides links to family support, information and advice on staying at home with children, and links to the Ethnic Minority National Resilience Network.

Non-UK Nationals

It is recognised that the travel and tourism industries may particularly be adversely impacted by these measures. 11.5% of the tourism sector’s workforce are non-UK EU nationals, compared with 5.8% for Scotland as a whole^[72]. As a result, non-UK nationals may be disproportionately impacted.

The Scottish Government has a dedicated resource related to advice for businesses^[73], and the Scottish Government’s Covid-19 guidance provides specific information/links in relation to the tourism sector. However, we will continue to take into account evidence of the impacts of the Regulations, and consider how they may affect one or more of the protected characteristics.

There may be a risk that the general population misunderstand the intention of these measures and assume all non-UK citizens in Scotland should be self-isolating. It is therefore crucial that messaging and communication that these measures are a requirement for all arrivals, subject to certain exemptions, is delivered across the UK. The public health checks at borders guidance provides information on these measures, and the Scottish Government will work internally and with the UK Government to ensure that the rights of those already in Scotland are not impeded by the new measures.

Gypsy/Travellers

Gypsy/Travellers who do not live in settled accommodation face some specific additional risks and vulnerabilities during the Covid-19 crisis – such as access to sanitation or a separate trailer to self-isolate - which may make it difficult for them to limit virus spread and comply with public health guidelines. In 2011, Gypsy/Travellers in Scotland, compared to the population as a whole, were more likely to report a long-term health problem or disability and were more likely to report bad or very bad general health^[74].

These should be considered within local resilience plans - for example, if space is needed to camp for the quarantine period. The impact of Covid-19 on Gypsy/Traveller travel patterns is unpredictable. The summer travelling season may result in travel from Ireland but, due to ferry routes, this will come through Northern Ireland.

To assist in the mitigation of any negative effects and to eliminate discrimination, the Scottish Government are currently working with Local Authorities^[75], while Ready Scotland’s additional support page^[76] provides links to information and guidance that has been produced for Gypsy/Traveller communities on coronavirus. A Facebook page, a joint initiative of partners including the Scottish Government, has been set up for Gypsy/Traveller communities to provide up to date information on coronavirus^[77].

Summary: Measures that may help limit the spread of coronavirus are designed to positively affect the entire population, but may particularly benefit people in the South Asian ethnic group. However, it is also noted a returning traveller required to self-isolate, and living in an overcrowded household, may find it more difficult to distance themselves from other members of their household, and this may potentially contribute to an increased risk of the spread of the virus within such a household. This may be particularly pertinent among people from minority ethnic groups (including among the South Asian ethnic group).

A new expert group will work with the Scottish Government to provide a clearer picture of the impact on minority ethnic communities of coronavirus, and advise on policy actions to mitigate any disproportionate effects^[78]. The Scottish Government will continue to take into consideration any newly identified evidence, in relation to any impacts the requirement to self-isolate for 14 days may have on minority ethnic people, and use this evidence to make changes, as appropriate.

The current border health measures guidance, which makes clear who the Regulations apply to, may help to eliminate discrimination against non-UK citizens in Scotland, and to foster good relations between people. Mitigating measures available to help Gypsy/Travellers - for example, existing guidance and support and the setting up of the Facebook page, may help to eliminate discrimination and advance equality of opportunity, by helping to provide support to Gypsy/Traveller communities.