People with communication needs and the Scottish social security system: fulfilling the expectations of ‘Our Charter’

The culture, skills, and attitudes of staff play a key role in making sure ‘Our Charter’s’ goals are met. The Scottish Government has invested significant resources in developing a staff team as a front door to Social Security Scotland’s services – with the aim of providing support throughout the process. How well is this approach serving people with communication needs?

Relevant Charter expectations

A people’s service

Social Security Scotland and the Scottish Government will:

1. be patient, kind and consider how you might feel.
2. listen to you, trust you and treat you as an individual.
3. treat everyone equally, fairly and without discrimination.
4. support you through your application, keeping you updated and explaining what will happen and why.

Processes that work

Social Security Scotland and the Scottish Government will:

3. adapt processes and ways of communicating as much as we reasonably can to meet your needs and preferences, for example by providing interpreters.
4. support your wellbeing and make your contact with us as positive and stress-free as possible.

A learning system

Social Security Scotland and the Scottish Government will:

5. ensure staff understand the needs of different people and the barriers they face – so that no-one experiences discrimination because of who they are.

2.1 The current evidence base

Research published in April 2019 highlighted that people accessing support from Social Security Scotland expected that staff should be ‘welcoming’, ‘open-armed’, ‘non-judgemental’ and ‘willing to help’.¹Scottish Government – Social Security Experience Panels: Social Security Scotland Staff

Client survey data from 2022/23²Social Security Scotland – Client Survey 2022-2023 allows us to compare the experiences of people with communication needs to those without.

• 46% (compared with 34%) of people with communication needs had been in contact with a staff member.
• 88% (compared with 92%) of those with communication needs rated their overall experience with staff as ’good’/ ’very good’.
• 82% (compared with 86%) of those with communication needs said staff were able to help them.

People with communication needs were also less likely than those without such needs to agree that they were treated with dignity, fairly or with respect.

2.2 Interactions with Social Security Scotland staff

During the research, participants with communication needs often considered their initial experience – whether positive or negative – of dealing with Social Security Scotland call handlers. This highlights the importance of this initial interaction.

Participants often contrasted individuals’ experiences with Social Security Scotland with their interactions with the Department for Work and Pensions, noting positive call handlers and clarity of approach by Social Security Scotland as positive steps forward.

Less positive experiences were also reported.

We heard that communications were not always delivered in an appropriate way. Often, this seemed to be due to a lack of understanding or flexibility in relation to the person’s communication needs. In one case, focus group participants highlighted that Social Security Scotland staff members had suggested they could not go further in the process unless the individual for whom the application was being made came to the phone.

Social Security Scotland has internal guidance on communicating with clients who are deaf, deafened, deafblind or hard of hearing. It covers the range of diverse needs people who are deaf or hard of feeling may require, and the services available for communicating with them.

In some cases, however, our research highlights that this may not have been followed.

While Social Security Scotland’s policies allow for this level of flexibility of approach to support for people with communication needs, in some cases this is not being experienced by clients. Some reported experiences suggest that the charter expectation to treat people equally, fairly and without discrimination may not always be wholly fulfilled.⁵See also Social Security (Scotland) Act 2018 s1(g) and the Social Security Scotland strapline of ‘dignity, fairness, respect’. The aim of “dignity, fairness and respect” could be undermined when the communication needs of people interacting with Social Security Scotland (whether to make a claim or simply a query) are not fulfilled.

In some cases participants felt that information that they had provided about their own condition was not used efficiently and that they often had to repeat their communication requirements as a result.

For example, when an individual had told one client adviser they had hearing loss, they thought it should be possible for all client advisers they dealt with in future to be made aware of this. Participants felt that more consistent use of this information would not only improve their experiences but also assist advisers’ understanding of the barriers the individual faced.

Focus group participants suggested that clear markers on claims indicating individual requirements would improve clients’ experiences and assist advisers in providing better support.

We understand that Social Security Scotland has a communications needs indicator that is included on a client record and clients are invited to share any communications needs or preferences during the application process. Clients are able to contact them to add a need or preference to their record and this can also be done through a change of circumstances form.

We noted some reluctance to needing to ask for help among participants, often a result of desiring to maintain independence and autonomy. Offering proactive assistance, rather than waiting for clients to make requests, was seen as a meaningful way to provide reassurance and leave clients feeling supported and at ease by the end of any interaction. This, however, is only going to be effective if there is sufficient (individual or institutional) knowledge of the sort of assistance that will be effective to the person in the circumstances.

Having to request help was described as impacting individuals’ sense of independence, often leading to a reluctance to seek assistance. However, participants indicated that proactively offered support might be more readily accepted.

This could, partly, be addressed by the actions Social Security Scotland have set out in their Inclusive Communication Action Plan 2022-2025, in particular, that they will set out what good inclusive communication looks like and monitor it,⁷Social Security Scotland – Inclusive Communication Action Plan 2022-2025, Asset 2, point 6: Ways of delivering inclusive communication 6. Set out what good inclusive communication looks like for us and how we will keep track of what we are doing. as well as delivering a plan for staff to learn inclusive communication skills.⁸Social Security Scotland – Inclusive Communication Action Plan 2022-2025, Asset 4, point 16: Create and deliver a plan for staff to learn inclusive communication skills, including finding new ways for staff to learn.

2.3 Consent for someone to act on your behalf

Some individuals may have a welfare rights adviser or support worker to assist them in making a claim. In such situations Social Security Scotland has to ensure that the individual has consented to have someone else act on their behalf. Social Security Scotland policies should allow for both authorised consent (where the client has provided clear consent for information to be shared with the third party representative) and unavailable consent (which is used to describe situations where Social Security Scotland cannot verify that consent has been given by the client, but an exceptional circumstance has occurred that allows Social Security Scotland to share general information with a third party representative to help them support the client)¹¹Social Security Scotland – Client representative guidelines. In some circumstances, however, participants highlighted that there were more barriers to obtaining consent than they had experienced under the Department for Work and Pensions benefits system.

Interview participants highlighted their concerns about waiting for, getting and using a ‘mandate’ (a form authorising third party representatives to have discussions with Social Security Scotland directly). Such delays could result in welfare rights advisers using the complaints process as a way to obtain a mandate, though this could further delay the process.

In some cases this was attributed directly to staff interpretation of data protection rules.¹⁵[1] Participants specifically mentioned the General Data Protection Regulation 2018 – which require any organisation that processes personal data to follow detailed handling rules.

2.4 Raising staff awareness

Participants emphasised the importance of creating an inclusive environment where everyone’s rights are fully recognised and upheld. To achieve this, they expected that disability equality training should be mandatory for Social Security Scotland staff including a focus on specific impairments such as sensory loss and neurodivergence.

In discussion with us, Social Security Scotland officials noted that measures are in place to review the quality of learning and development and that inclusive communication is a key part of training for staff joining Social Security Scotland.

Such awareness training should ensure a deeper understanding of individuals’ diverse needs and align with the Social Security Charter’s principles of dignity, fairness, and respect. Social Security Scotland should keep the appropriateness of its training under review and consider what can be done to ensure staff consistently act in accordance with it.

2.5 Fulfilling charter expectations

Relevant charter expectations are highlighted in bold.

Focus group participants highlighted positive experiences of patience, kindness and consideration.

There were, however, instances where people with communication needs did not feel they were listened to, trusted or treated as an individual. Whilst consistent advice on how to apply, appeal or manage each benefit is important, this could be balanced with a more flexible, individualised approach to take account of their needs.

In such circumstances, participants felt that this experience could be improved by training to extend staff understanding the needs of different people and the barriers they face, and that this in turn would help ensure everyone is treated fairly and without discrimination.

It was noted that in some cases advice about consent was inconsistent and did not reflect publicly stated policies. This could undermine attempts to ensure that people know they are entitled to ask someone that they know to support them.

2.6 Recommendations

Recommendation 1: To ensure people don’t need to repeatedly tell Social Security Scotland about their individual communication needs, Social Security Scotland should ensure an accurate record of people’s communications and access requirements is kept, maintained and used by staff.

Recommendation 2: To ensure individuals receive appropriate communications support, Social Security Scotland should monitor and regularly review the types of support its client base may require.

Recommendation 3: To enable people with communication needs to express consent for a third party to act on their behalf, Social Security Scotland should consider if there are ways to improve the way it obtains consent.