Scottish Social Services Council (SSSC) – proposed register changes: consultation analysis

5. Analysis

There were four questions in the consultation document which related to the proposed changes to the SSSC register. Three of the questions asked for yes/no answers on whether the respondent agreed with the proposed changes or not. There was also an option to select 'not sure' if the respondent didn't have a specific view on any of the questions. The fourth question provided an opportunity for respondents to provide additional comments on the proposed changes that they would like to be considered further.

The below analysis follows the layout of the consultation document.

All questions which asked for a "yes" or "no" answer have been broken down into the following categories for responses:

Yes – the respondent selected "yes" when answering the question

No – the respondent selected "no" when answering the question

Don't know – the respondent selected "don't know" when answering the question

Not answered (NA) – the respondent did not answer the question and made no comments about the proposal

Question 1

Do you agree that reducing the number of SSSC Register parts will be an improvement to the current structure?

60 respondents agreed with the overarching policy detailed in the consultation; 4 respondents did not agree and 5 respondents were unsure.

15 respondents provided further detail about this question. A snapshot of responses can be found in the analysis for question 4 where key themes have been identified.

Full responses (from those who gave consent to publish) can be found at:

Published responses for Scottish Social Services Council – proposed register changes - Scottish Government consultations - Citizen Space

Question 2

Is three months after starting in their role an appropriate timescale to require workers to apply for registration?

53 respondents agreed that 3 months is an appropriate timescale to require workers to apply for registration. 14 did not agree and 2 respondents were unsure.

19 respondents provided further detail about this question. A snapshot of responses can be found in the analysis for question 4 where key themes have been identified.

Question 3

Do you agree with SSSC's proposals to include more information on the searchable public Register?

53 of the respondents agreed with the proposals to include more information on the searchable public register. 9 respondents did not agree, whilst 6 respondents were unsure. 1 respondent did not answer the question.

17 respondents provided further detail about this question. A snapshot of responses can be found in the analysis for question 4 where key themes have been identified.

Question 4

Do you have specific views on the proposed changes that you would like us to consider?

38 respondents responded to this question, providing further views on the proposed changes referred to in the previous 3 questions. Key themes have been identified from the responses where similar views have been shared by several respondents.

Below is a snapshot of the responses.

Reducing the number of register parts

Response no. 1

In terms of both staff and the public, this approach would be welcomed as it would improve accessibility through having a reduced number of parts within the register to navigate. It would also be beneficial to staff moving between services or when gaining a promotion as they would no longer need to remove themselves before reapplying to the correct part of the register.

Response no. 2

The process must be as simple and streamlined as possible for managers or individuals to change and update level of role if staff are promoted or move jobs.

Response no. 3

In the application's current form, it is needlessly long and time consuming. Reducing the number of parts will make it far easier for social care workers to register under the SSSC and will therefore increase the number of people who are willing to register and also ensure increase the likelihood for the forms to be completed properly therefore reducing administration and waiting times.

As the form will be shorter, this should and must result in quicker turnaround of applications and decisions for applicants which will make it easier and faster for them to join the workforce. This is especially important given the current recruitment and retention crisis in the social care sector.

Fewer parts will also make it easier for social care workers to move between different roles whilst having just one registration rather than having to apply for one of the twenty-three parts and fill in a new application each time.

Response no. 4

There is an issue with the number of parts of the register. Whether reducing to four is perhaps being too simplistic is another matter.

Response no. 5

Simplifying the register will make it easier and hopefully quicker for employees applying to register. If it also reduces the need to have more than one registration to work across different resources ie: housing support and residential care homes, this will reduce costs to both employees and employers who cover the cost of registration. All in all everyone benefits.

Key Themes

The responses to this particular question on reducing the number of Register parts were mostly positive, with a vast majority of respondents agreeing with the proposals. However, a few of the responses highlighted areas that still needed to be considered before implementing the proposed changes. It was pointed out that any changes could add an additional burden on SSSC staff during the transition phase which would need to be managed carefully.

It was highlighted that Residential child care should be retained as an independent category on the SSSC Register. It was also suggested that although this is a positive change, the reduction in the categories from 23 to 4 may limit the amount of data SSSC can gather about the workforce.

The main themes coming through about this proposals were that by reducing the number of Register parts, it should make the current complex process of registering easier and more streamlined. It would improve accessibility, whilst also making it easier to move between different roles as it would limit the number of people having to reregister on a different part of the Register. It was also mentioned several times that by reducing the number of Register parts, it should make the registration process quicker, ensuring applicants can join the workforce faster.

Timescales for Applying

Response no. 1

As three months is the probationary period in many settings, it may not be realistic for staff to register within the first three months. Safer recruitment procedures should allow settings to determine suitability.

Response no. 2

While this change is likely to be beneficial in terms of public protection, there may be infrastructure changes that may be needed to facilitate this change. In addition, it would need to be clear whether the proposed three month timeframe covers just the submission of an application, or whether it would also include the processing. If the intent is for the latter timeframes, then any backlog of applications would need to be
closely managed and kept as small as possible so as not to negatively impact or
disadvantage new registrants.

A reduced timeframe to three months would also put pressure on line managers, where assisting staff in their registration is a small part of their role. Which may mean that there is slippage due to capacity or more pressing issues possibly leading to unintended consequences elsewhere within a service.

Also, would there be any mitigations, or consequences regarding circumstances
where an individual is unable to uphold registration within the proposed three month time period? As a reduced timeframe may impact upon some people registering punctually, a period of implementation may be advised to identify any issues that could be mitigated if this proposal is agreed.

Response no. 3

The proposed three-month timescale to apply for registration recognises the importance of achieving registration in a timely way.

Response no. 4

The move to 3 months registration will require widespread communication with employees and employers to ensure they know their obligations.

Response no. 5

Registration should be required within 1 month of starting a job. There should be more time given to achieve qualifications for new entrants to the care industry.

Key Themes

The majority of responses to this question were also positive, however those who did provide a written contribution highlighted some concerns around the proposes to reduce the timescales for applying for registration. The main concern was that three months is too short a timescale to expect a new worker to apply for registration. Some respondents highlighted that workers shouldn't have to apply for registration until their 6 month probationary period has been completed.

It was suggested that changing the timescales for applying could put additional pressure on individuals, managers and organisations, and that any changes would need to be communicated early to ensure no one was disadvantaged by the shortening of the time period workers have to apply.

Alternatively, there were some comments supporting the proposals to reduce the timescales for applying to register, highlighting that by doing so would increase public protection.

Changes to the Public Facing Register (PFR)

Response no. 1

I think this is so needed making it easier for staff to see full details and sanctions for new staff members looking to bring out teams.

Response no. 2

Changes would include detail of registration e.g. manager/supervisor etc. This would be crucial if the registration parts are to reduce from 23 to 4.

Changes would display qualifications held. This would promote importance of qualifications.

Fitness to Practise warnings and/or conditions is available but on a different page on the website and is not linked to the individual's record. Linking the information would show all relevant information about the individual's registration and information less likely to be missed. This would be particularly useful for Recruiting Managers.

Response no. 3

In relation to the proposed changes to the searchable public register we continue to have concerns that some of this information might be mis-interpreted by some members of the public. For example, a false allegation raised against an individual can, understandably, result in a temporary suspension in order to enable investigation yet members of the public might make unwarranted assumptions of guilt. While we recognise the desire to bring the SSSC in line with the NMC we feel this may disproportionately affect staff in social care, particularly in lone working community-based situations.

Response no. 4

The second part of this proposal is for SSSC to publish FtP information on its public register, and it cites the NMC as an example of a regulator that already takes this approach. We strongly support this proposal as it will ensure that register users can easily access a complete picture of any regulatory sanctions that apply to professionals, which is vital for public protection.

Response no. 5

In relation to the proposals to include more information on the public register, specifically whether there is a fitness to practise warning and/or condition against a registrant, we are of the view that providing this information is an important public protection and as with the proposal above, we agree that this proposal will enhance public confidence in the sector.

Key Themes

The responses to this proposal to include more information on the Public Facing Register also received a majority of positive responses. There were also some responses highlighting concerns about sharing this additional information, with the main concerns being around the impact on the individual concerned. Some respondents noted that information may be misinterpreted by the public, therefore putting additional pressure on the registrant.

Others highlighted that including additional information on the Public Facing Register may put additional pressure on workers, which could in turn exacerbate recruitment and retention issues.

It was also stressed that any information that is published on the register would need to be accurate and be kept up to date.

Concerns raised have been expanded on in the Scottish Government Response section of this report.