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

7. Scottish Government Response

As outlined within the executive summary section of this document, this consultation followed a more detailed consultation that the Scottish Social Services Council (SSSC) ran between 20 December 2021 until 14 March 2022. Over 6500 people responded to this particular consultation, with the majority of respondents agreeing with the proposals.

As a result of this, and the positive response to this consultation, the Scottish Government intend to proceed with the proposals to make three changes to the SSSC Public Facing Register as outlined in this document. The changes are as follows:

• Reduction of the Register to Four Parts – This will simplify and streamline the registration process, making it less time consuming and confusing for applicants. It will reduce the need for people to be registered on multiple parts, and make the process of being promoted or changing service much more straightforward.
• Reduce the Timescales for applying to 3 months – This change would mean there is a requirement for workers to apply for registration within 3 months of starting a new role, and be registered within 6 months. This will mean that workers will apply for registration sooner which will allow the assessment of an applicant's Fitness to Practise at an earlier stage, providing greater public protection. Several respondents highlighted concerns over this change, stressing that 3 months isn't enough time to expect a worker to apply to register. In order to alleviate concerns, SSSC will produce a communications plan, whilst also engaging extensively with stakeholders to ensure employers and workers are aware of the new responsibilities.
• Make changes to the Public Facing Register – This will mean more information will be made available to the public. This change will give greater transparency by providing ease of access to the information related to an individual. This would include the level of role, whether an individual has a qualification or specialist qualification for their role and whether the individual has any Fitness to Practise warnings. This will improve access for those who use services to public protection information. The main concerns that have been identified throughout the analysis process are the potential negative impact sharing this additional information may have on an individual. This is true for both the publication of qualifications and also Fitness to Practise information.

Initially, SSSC will only publish specialist qualifications (mental health officer awards and practice educator awards), but only where the worker has consented to this. General qualifications will not be published immediately due to the current imbalance across the sector regarding qualifications. The SSSC will move to publish this information once there is greater balance across the sector. The principle behind this change is to have a more qualified workforce.

At present, the SSSC do not include Fitness to Practise information on the Public Facing Register, however, this information is published on another area of the website, and is easily accessible to the public. The proposed changes to include additional information on the Public Facing Register will improve public protection by making the information already held in other areas of the website more streamlined and easier to access. Including this information on the Public Facing Register will bring SSSC in line with other equivalent regulators such as the General Medical Council in terms of information published. It is also true that the SSSC have discretion to withhold information regarding any removals or suspensions from the register if disclosing such information could be considered to cause danger to the person to whom the entry relates.