Transparency and ethics
This page provides links to a variety of sources that help inform about:
- the vaccine and the people who have been allocated into priority groups for vaccinations (we call them cohorts)
- the organisations involved in delivering this challenging programme
- how we use your data
- ethical considerations and other impact assessments undertaken
Immunisation policy in Scotland is set by the Scottish Government on the advice of the Joint Committee on Vaccination and Immunisation (JCVI) and other appropriate bodies.
The coronavirus (COVID-19) vaccine
The coronavirus vaccination programme aims to rapidly vaccinate the eligible population of Scotland.
A suite of digital products is being deployed to support, monitor and manage the scheduling of vaccinations, data capture and sharing across the health and care environment.
Additionally, some of these products will be deployed to enable people to interact with their vaccination journey.
Cohorts and risk stratification: prioritising who has to be vaccinated first
The Joint Committee of Vaccination and Immunisation (JCVI) have set out a vaccinations prioritisation list for people at risk across the different population groups.
A full Health Inequalities Impact Assessment (HIIA) was carried out by Public Health Scotland (PHS) to identify and assess potential impacts of the coronavirus vaccination programme on different population and protected characteristic groups e.g. people with protected characteristics, those of differing socioeconomic circumstances.
The purpose of the HIIA is to identify any barriers to the uptake of the coronavirus vaccination across the current population and protected characteristic groups and potential actions to address this.
Our Senior Clinicians sometimes called Caldicott Guardians have been ambassadors of a set of principles to protect the privacy and confidentiality rights of patients even before Data Protection legislation was in place.
Along with the Caldicott Guardian Principles and Data Protection legislation, Scottish Government and public sector organisations have developed an Ethical Framework for data and digital information systems.
The framework is used to assess the ethicals impact of these systems and covers key values and principles.
The ethical considerations for the vaccination programme will be examined and set out in an Ethics Assessment.
The assessment will be published shortly and will continue to be reviewed throughout the vaccine programme.
The ethical considerations will follow the principles set out above and focus on areas not already covered by the individual impact assessments.
Key stakeholders will be engaged in helping develop this assessment.
Equality impact assessment
The Equality Impact assessment is about testing the Vaccination Programme against the needs of the general equality duty in the Equality Act 2010, and considering how it will affect people with protected characteristics, prevent discrimination and identify opportunities to promote equality.
It will be published shortly.
We are engaging with key stakeholders who will support the ongoing development of the Equality Impact Assessment.
How we use your data: Privacy Notice
Privacy and data security are very important to the Scottish Government and health boards within the NHS in Scotland and we take our legal obligations seriously.
As such, robust measures have been put in place to ensure all systems and processes within the coronavirus (COVID-19) Vaccination Programme have been designed with these in mind and as a priority.
For more information read the full privacy notice
Data Protection Impact Assessment
Individual Data Protection Impact Assessments (DPIAs) exist or are being developed for each of the systems and data flows.
An overarching narrative is being developed that will explore, in a transparent way, how the data protection principles and rights of the population in Scotland have been met across the various data flows involved in the COVID-19 Vaccination Programme.
The document will be published shortly and should be read in conjunction with the privacy notice.
We are working with a wide range of organisations to help us take into account their views and understand the impacts that the vaccinations programme may bring.
Key stakeholders include, but are not limited to, the following:
- Royal National Institute of the Blind (RNIB)
- Deaf Scotland
- Health and Social Care Alliance Scotland
- NHS 24
- Higher Ground Health Care Planning (HGHCP)
- The Equality Network
- Age Scotland
- Inclusion Scotland
- Scottish Commission for People with Learning Disabilities (SCLD)
- Young Scot
23 November 2022
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