Decision

The analysis undertaken for this Consumer Duty Impact Assessment has highlighted that there will be direct and indirect effects on consumers. The NSWA will continue to deliver trauma responsive training, engage in workforce and education planning, and devise standards and guidance.

Those most directly affected will be the social work profession (including students), employers of social workers and third and independent sectors delivering commissioned services. The indirect consumers include: people who use social work services, advocacy and membership organisations (e.g. Scottish Association of Social Work) and regulators like the Scottish Social Services Council. 

Consideration of the evidence has indicated how the NSWA will meet the objectives of the Consumer (Scotland) Act 2020: 

Reduce harm to consumers in Scotland

With its focus on improving the standards of social work services delivered, this should avert and negate any potential harm to consumers. Moreover, ongoing consultation with the social work profession, recipients of trauma training and those with lived experience of social work, should ensure issues are addressed. 

Increasing confidence among consumers in Scotland in dealing with businesses that supply goods and services

By raising the standards of the social work profession, consumer confidence in the services delivered should improve. Similarly, the delivery of trauma responsive training by the NSWA is iterative in nature, seeking feedback and making ongoing changes as required.  

Promote sustainable consumption

NSWA will encourage sharing of resources and platforms where possible to allow for sustainable choices to be made. For example, if holding a training session or engagement event requiring travel, this would ideally be completed in one session rather than multiple ones to save people having to travel multiple times. 

Advance inclusion, fairness, prosperity and other aspects of wellbeing in Scotland

NSWA will develop and publish an Equalities Strategy documenting considerations for ways to promote inclusivity, fairness and equality. Part of this will involve building upon existing anti-racism work that has been undertaken. The wellbeing of the profession will also be at the forefront of the NSWA’s work. 

While the results indicate that direct and indirect consumers will likely be impacted by the establishment of the NSWA, these are believed to be positive in nature. An extensive MCDA interrogated the possible options from a longlist of seven and a shortlist of three. Rankings indicated that the establishment of the NSWA as an executive agency has the strongest performance across all criteria and has robust support from partners. Furthermore, it was found to be the most cost-effective option (aside from the ‘Business as usual’ option; however, that scored low on almost all identified criteria). The policy proposed has the greatest ability to deliver the change required for the social work profession. 

Further engagement will take place with business stakeholders during the development of the interim corporate plan, as well as the implementation stage. Feedback from stakeholders will inform any necessary adjustments to the scope, structure and operations policy to the NSWA. 

We have concluded that additional targeted consumer engagement will be required during implementation to ensure ongoing compliance with the Consumer Duty. This will include engagement with people with lived experience, students, carers, vulnerable service users, and small providers to ensure impacts are fully understood and mitigations remain effective. This engagement will form part of the NSWA’s implementation and annual planning.

In conclusion, officials are satisfied that the NSWA model represents the option most capable of improving outcomes for consumers, reducing harm, and promoting fairness, transparency and national consistency. The analysis demonstrates that the Duty has been met, and that appropriate mechanisms are in place to ensure continued compliance through implementation, monitoring and post implementation review.