Flu and COVID-19 vaccination programme 2023-2024: child rights and wellbeing impact assessment

CRWIA Stage 2 – Assessment of Impact and Compatibility

1. What evidence have you used to inform your assessment? What does it tell you about the impact on children’s rights?

As with other vaccines in Scotland, the evidence we have used to inform our assessment has come from the JCVI, who in turn have based their assessment on all emerging scientific data on COVID-19. More information on the evidence can be found at Joint Committee on Vaccination and Immunisation - GOV.UK (www.gov.uk).

The JCVI recommended that the childhood element of the Seasonal Influenza Programme is a cost effective element that provides population protection and minimises transmission of Seasonal influenza. Following further consideration in December 2021, the JCVI remained supportive of fully extending the childhood programme on a routine basis which they consider to be highly cost effective as per their original recommendation in 2012.

2. Evidence from stakeholders/Policy Colleagues

Currently we do not hold the full data picture of COVID-19 vaccinations for 2023 uptake in children at risk as childhood programmes have been behind with regards to the rollout of COVID-19 vaccinations. Some Health Boards have only just completed dose 2 for some childhood cohorts in summer 2023.

In regards to flu vaccination, in 2022/23 winter period an estimated 595,191 eligible children and young people in schools have been given their vaccination resulting in a 66.5% uptake. In winter 2023/24, 538,606 vaccinations have been administered thus far; although the winter flu vaccination programme is still ongoing, this shows a drop in uptake for the flu vaccinations this year.

Public Health Scotland has and will continue to engage with parents and carers to ensure they are fully informed when it comes to making the decision on whether their child is vaccinated. Section 2.2 highlights the work that has been undertaken this year to engage with those caring for children and to ensure that any marketing is tailored to young people. The Scottish Government has engaged with disability and unpaid carers policy teams in order to inform policy decision making for COVID-19 and flu vaccination of children and young people.

The Scottish Government remains committed to its vaccination programmes and we strongly recommend that individuals eligible to receive vaccinations do so. It should be noted however that COVID-19 and Seasonal Influenza vaccinations are not mandatory, therefore this policy is based on voluntary uptake of the offer of vaccination by children and young people.

In all instances, the offer of vaccination must be accompanied by appropriate information to enable children and young people, and those with parental responsibility, to be adequately able to appraise the potential harms and benefits of vaccination as part of the informed consent process prior to vaccination.

3. Evidence from children and young people

All of the decisions related to the vaccination of children and young people have been taken in the best interests of children and young people, as well as to promote health, wellbeing and safety.

For this CRWIA we have consulted with parents and carers, but had minimal consultation with children and young people on our vaccination policy. We will attempt to rectify this for future iterations.

While children and young people have not been directly consulted on the use of COVID-19 vaccine, we have engaged with parents and carers and the following organisations representing the interests of children and young people.

• Children's Health Scotland
• National Carer Organisations (NCOs)
• Connect
• Down's Syndrome Scotland
• Parenting across Scotland
• Voluntary Health Scotland

Prior to the COVID-19 vaccination roll out for 5-11 year olds, Public Health Scotland (PHS) undertook some focus work groups and issued a short survey in March 2023 for parents and carers to provide their input, as they developed child-centred COVID-19 vaccination materials for children aged 5 to 11 years. As part of this parents and carers reported on what their children wanted to know about COVID-19 vaccination. The survey was advertised via PHS social media and shared directly with the following organisations: Coalition of Carers in Scotland, Carers Trust (Scotland), Children in Scotland, Children’s Health Scotland, CHAS, Connect, Down Syndrome Scotland, Family Fund, National Parent Forum of Scotland, One Parent Families Scotland, Parent Club, Parenting across Scotland and Voluntary Health Scotland.

Alongside the work by PHS, we have funded MECOPP to undertake qualitative research exploring what Gypsy Travellers think of vaccine information resources and how they can be improved to reflect cultural realities, which has included a focus on young people’s information resources. The report can be found online.

Analysis of the evidence

4. How have the findings outlined in questions 1-3 influenced the development of the relevant proposal?

When formulating advice in relation to vaccination of children and young people, the JCVI have consistently held the view that the main focus of their considerations is the potential benefits and harms of vaccination to children and young people themselves.

Different cohorts of children and young people have become eligible for vaccination at different stages of the programme, as per JCVI advice, based on clinical and other risk factors, with those at higher risk of severe COVID-19 outcomes being prioritised.

Full details regarding the JCVI advice which outlines what groups became eligible and when and for how many doses the should be give can be found at JCVI COVID-19 vaccination of children - GOV.UK (www.gov.uk).

5. Assessing for compatibility against the UNCRC requirements

UNCRC Articles

What impact does/will your relevant proposal have on children’s rights (Please tick positive, negative or neutral)

Article 1 Definition of the child

Positive X

Negative

Neutral

For the purposes of the present Convention, a child means every human being below the age of eighteen years

Article 2 Non-discrimination

Positive X

Negative

Neutral

Article 3 Best interests of the child

Positive X

Negative

Neutral

Article 4 Implementation of the Convention

Positive X

Negative

Neutral

Article 5 Parental guidance and a child’s evolving capacities

Positive X

Negative

Neutral

Article 6 Life, survival and development

Positive X

Negative

Neutral

Article 7 Birth registration, name, nationality, care

Positive

Negative

Neutral X

Article 8 Protection and preservation of identity

Positive

Negative

Neutral X

Article 9 Separation from parents

Positive

Negative

Neutral X

Article 10 Family reunification

Positive

Negative

Neutral X

Article 11 Abduction and non-return of children

Positive

Negative

Neutral X

Article 12 Respect for the views of the child

Positive X

Negative

Neutral

Article 13 Freedom of expression

Positive X

Negative

Neutral

Article 14 Freedom of thought, belief and religion

Positive X

Negative

Neutral

Article 15 Freedom of association

Positive X

Negative

Neutral

Article 16 Right to privacy

Positive

Negative

Neutral X

Article 17 Access to information from the media

Positive X

Negative

Neutral

Article 18 Parental responsibilities and state assistance

Positive X

Negative

Neutral

Article 19 Protection from violence, abuse and neglect

Positive

Negative

Neutral X

Article 20 Children unable to live with their family

Positive

Negative

Neutral X

Article 21 Adoption

Positive

Negative

Neutral X

Article 22 Refugee children

Positive X

Negative

Neutral

Article 23 Children with a disability

Positive X

Negative

Neutral

Article 24 Health and health services

Positive X

Negative

Neutral

Article 25 Review of treatment in care

Positive

Negative

Neutral X

Article 26 Social security

Positive

Negative

Neutral X

Article 27 Adequate standard of living

Positive

Negative

Neutral X

Article 28 Right to education

Positive X

Negative

Neutral

Article 29 Goals of education

Positive

Negative

Neutral X

Article 30 Children from minority or indigenous groups

Positive X

Negative

Neutral

Article 31 Leisure, play and culture

Positive

Negative

Neutral X

Article 32 Child labour

Positive

Negative

Neutral X

Article 33 Drug abuse

Positive

Negative

Neutral X

Article 34 Sexual exploitation

Positive

Negative

Neutral X

Article 35 Abduction, sale and trafficking

Positive

Negative

Neutral X

Article 36 Other forms of exploitation

Positive

Negative

Neutral X

Article 37 Inhumane treatment and detention

Positive

Negative

Neutral X

Article 38 War and armed conflicts

Positive

Negative

Neutral X

Article 39 Recovery from trauma and reintegration

Positive

Negative

Neutral X

Article 40 Juvenile justice

Positive

Negative

Neutral X

Article 41 Respect for higher national standards

Positive

Negative

Neutral X

Article 42 Knowledge of rights

Positive X

Negative

Neutral

6. Impact on children and young people

This impact assessment considers the impacts to children's rights and wellbeing in relation to the COVID-19 and Seasonal Influenza vaccination policy and programme implemented throughout Scotland.

The assessment considers all children and young people, while specifically highlighting implications for children and young people who may be at greater clinical risk from a COVID-19 and Seasonal Influenza infections. This includes those with underlying health conditions, and examines what steps have been taken to mitigate the impacts for these groups.

Assessment of the vaccination policy conveys an overall positive impact on the United Nations’ Convention on the Rights of the Child (UNCRC) for all children and young people.

7. Negative Impact/Incompatibility

No negative impact of the policy has been identified. However, just as with any medical product COVID-19 vaccination may, on rare occasions, result in adverse events.

The Medicines and Healthcare products Regulatory Agency (MHRA) is the organisation that is responsible for the authorisation and safety monitoring of vaccines. The MHRA keep the safety of all vaccines under close and continual review and Ministers will immediately take appropriate action if new evidence emerges which called into question the safety of any vaccines currently in use in Scotland. In addition to making the approval for safety and publishing known side effects of COVID-19 vaccines, the MHRA provides continual monitoring of any new or suspected new adverse reactions. This is done through the Yellow Card Scheme which can be used to report side effects.

As with all other vaccinations in Scotland, COVID-19 and flu vaccines are not mandatory and as mentioned earlier in the document, we have worked with PHS to ensure that both parents and children are aware of the informed consent process when it comes to vaccinations.

No negative impact of the policy has been identified in relation to the Seasonal Influenza offer as there is an alternative for those who cannot receive the nasal spray, or do not want it for religious or philosophical beliefs.

8. Options for modification or mitigation of negative impact or incompatibility

What options have been considered to modify the existing legislation or decision or relevant proposal in order to mitigate negative impact or potential incompatibility issues?

Please summarise mitigation actions taken in the below table:

Mitigation table

Issue or risk Identified per article/ Optional Protocol	Action Taken/ To Be Taken	Date action to be taken or was taken
Article 6 Life, survival and development Article 24 Health and health services COVID-19 vaccination safety and side effects	The MHRA keep the safety of all vaccines under close and continual review and Ministers will immediately take appropriate action if new evidence emerges which called into question the safety of any vaccines currently in use in Scotland	Ongoing
Article 12 Respect for the views of the child Article 24 Health and health services Article 42 Knowledge of rights Lack of informed choice / consent	PHS develops a range of informed consent materials to support parents, carers and children to understand the benefits and risks of vaccination and make a decision about receiving it. Vaccination staff are also trained to answer questions and explain about vaccines and will engage with every patient’s individual needs. Patient’s of all ages will have their decisions regarding vaccination respected.	Ongoing
Article 14 Freedom of thought, belief and religion Article 24 Health and health services Choice of alternative vaccine, where available, due to religious or philosophical beliefs	An alternative vaccine is available for those who cannot receive the nasal spray, or do not want it for religious or philosophical beliefs.	Ongoing
Article 24 Health and health services Children who are not eligible for COVID-19 or flu vaccination	We follow the independent advice of the JCVI regarding eligible cohorts in Scotland. This advice is based on clinical and cost effectiveness rationale. Some children are not eligible for COVID-19 vaccination however patients aged 12 and above may now be able to purchase a private COVID-19 vaccines from some pharmacies.	Ongoing

9. Positive impact: Giving better or further effect to children’s rights in Scotland

The Scottish Government has made it clear that children and young people and their parents, will be supported in their decisions and will not be stigmatised, whatever decision they reach on the vaccination offer. Individual choice will be respected.

The impact assessment found that overall the vaccination policy will have a positive impact, as it will help mitigate both the health and wider social harms that children and young people have experienced throughout the pandemic and will help support Scotland’s intent of managing and living safely with COVID-19.

There is a strong recognition that play and social interactions, with friends and wider family, plays a key role in optimising children’s development and wider wellbeing.

Children and people have been severely impacted by the COVID-19 pandemic with normal educational, cultural, sporting and social activities.

Therefore, the vaccination of children and young people supports the Scottish Government’s efforts to return to a more normal way of living and should help prevent more restrictive measures, such as lockdowns, being put into place in the future.

10. Impact on Wellbeing : does or will the relevant proposal contribute to the wellbeing of children and young people in Scotland?

Wellbeing Indicator	Will there be an improvement in wellbeing in relation to this indicator: yes/no
Safe - Growing up in an environment where a child or young person feels secure, nurtured, listened to and enabled to develop to their full potential. This includes freedom from abuse or neglect.	Yes
Healthy - Having the highest attainable standards of physical and mental health, access to suitable healthcare, and support in learning to make healthy and safe choices.	Yes
Achieving - Being supported and guided in learning and in the development of skills, confidence and self-esteem, at home, in school and in the community.	Yes
Nurtured - Growing, developing and being cared for in an environment which provides the physical and emotional security, compassion and warmth necessary for healthy growth and to develop resilience and a positive identity.	Yes
Active - Having opportunities to take part in activities such as play, recreation and sport, which contribute to healthy growth and development, at home, in school and in the community.	Yes
Respected - Being involved in and having their voices heard in decisions that affect their life, with support where appropriate.	Yes
Responsible - Having opportunities and encouragement to play active and responsible roles at home, in school and in the community, and where necessary, having appropriate guidance and supervision.	Yes
Included - Having help to overcome inequalities and being accepted as part of their family, school and community.	Yes

Post Assessment Review and sign-off

11. Communicating impact to children and young people

How will you communicate to children and young people the impact that the relevant proposal is having or will have on their rights?

We will reach out to the organisations that we engaged with during this process, to communicate the impact of the policy on children. We will work with Public Health Scotland (PHS) to continue our engagement with parents and young children and another CRWIA will be produced for 2024/25.

Are you publishing a child-friendly or accessible CRWIA?

Children will be able to access this CRWIA under the supervision of their parents and carers should they wish as it will be published on the Scottish Government website.

12. Planning for the review of impact on child rights

The JCVI will continue to review data on the potential benefits and risks of vaccination of children and young people.

As ever, we will continue to deliver vaccines in line with the advice received from the JCVI and should the JCVI make further recommendations for vaccination for this group, we stand ready to implement any advice as soon as possible.

As this assessment is dependent on the advice of the JCVI, which is subject to change, we will review this document next year when we receive advice from JCVI on the winter COVID-19 and flu programme and any changes will be communicated through a separate CRWIA for 2024-2025.

Compatibility sign off statement

This relevant proposal has been assessed against the UNCRC requirements and has been found to be compatible.

Policy Lead Signature & Date of Sign Off: Peggy Winford; 04 April 2024

Deputy Director Signature & Date of Sign Off: Dr ST Cuthbert-Kerr, Deputy Director for Public Health Capabilities, 4 April 2024

SGLD Sign Off:

Yes X

No