The Welfare Foods (Best Start Foods) (Scotland) Amendment Regulations 2023: equality impact assessment

Recommendations and Conclusions

The EqIA process has identified that the Welfare Foods (Best Start Foods) (Scotland) Amendment Regulations 2023 have potential to have positive impacts for those who share protected characteristics.

The main risk to the desired outcomes being achieved is if eligible individuals are not aware of their entitlement or the relevant procedural rules which can help to maximise their entitlement. To ensure that awareness is raised, a comprehensive communications and engagement strategy is being developed alongside the regulations which will include working with partner agencies to ensure that appropriate signposting is provided and that applicants can access the necessary information and be suitably supported throughout the process. We will also ensure that there is clear guidance for both decision makers and applications.

Barriers have been identified for specific groups as part of this Equality Impact Assessment. These are as follows:

Young parents

The current advertising and promotional materials for the FFP state that you may be eligible if you receive certain benefits or tax credits. However, this is not true for young parents or carers who are eligible or whose children are eligible if they are under 18, without the need to receive a qualifying benefit, provided the residency conditions are met. Following changes, dependants aged 18 or 19 years old and their children will also be eligible without the need to receive a qualifying benefit, provided the parent or carer meets the residency conditions. Without targeted messaging this group may not realise they are entitled to BSF resulting in lower awareness and take-up. To address this our communications and engagement strategy includes bespoke messaging and activities to ensure awareness is raised among this group. Social Security Scotland is conducting user research to understand the experiences of 16-24 year olds. Insights from this research will inform how we communicate with these young people.

Disabled people

A recent accessibility audit has highlighted that not all sections of the online information or application form are accessible to those with a disability. Without improvements to accessibility, those with a disability may not be aware of their entitlement or able to apply in a way that suits their needs. We have begun implementing the improvements identified and will continue to deploy these to ensure that our online systems are fully accessible.

Ethnic minorities

While the evidence suggests those from ethnic minorities are more likely to be eligible for BSF, the diversity and equalities data around applications does not suggest particularly high representation of these groups. Without a targeted approach to comms and engagement with these groups they may have less awareness of their entitlement and potentially have lower take-up than other groups. To address this our communications and engagement strategy includes working with relevant stakeholders and ensuring we promote BSF in locations that are particularly relevant to those from ethnic minorities.

Individuals for whom English is not their first language

The BSF evaluation highlighted that some recipients who do not speak English at all or who have English as a second language, experience issues with the application process for BSF. Some stated that they would like the option of choosing to receive communication (e.g. application form, decision letter, guidance) in other languages, or access to a translator. Social Security Scotland already provide the option to have guidance and letters in over 100 different languages and can provide access to translation services. However, if awareness of this is not raised then individuals may continue to face barriers in applying for BSF. To address this our communications and engagement strategy includes working with relevant stakeholders and ensuring we promote the availability of translation and interpretation services.