Freedom of Information (FOI) Request

Reference Number:

FOI-010726

Fulfilment Date:

22/07/2026

Topic:

Whistleblowing

Request:

1. How many incidences of whistleblowing has Independent Living Fund Scotland recorded in each of the last five financial years (please break down by year, 2021/22, 2022/23, 2023/24, 2024/25, 2025/26)?
2. Does your whistleblowing policy encourage or direct whistleblowers to raise concerns with a "prescribed person" (as defined under the Public Interest Disclosure Act 1998)? If so, please specify which prescribed person(s) are referenced.
3. Does your whistleblowing policy or process guarantee anonymity to individuals who raise a concern? If so, please provide a copy of the relevant section of the policy addressing this.
4. Does your whistleblowing policy include a non-recrimination or non retaliation provision, protecting whistleblowers from detriment or reprisal as a result of raising a concern? If so, please provide a copy of the relevant section of the policy addressing this.
5. Has your internal whistleblowing policy been subject to any External review, audit, or assessment (by an external body, auditor, regulator, or independent consultant) within the last five years? If so, please provide:
   a. the name of the body/organisation that conducted the review;
   b. the date of the review; and
   c. a copy of any resulting report or summary of findings, subject to any applicable exemptions.

Response:

1.ILF Scotland had no incidences of whistleblowing during 2021/22, 2022/23, 2023/24, 2024/25 and 2025/26.

2. ILF Scotland staff are encouraged to raise concerns with the following prescribed persons: Line manager; Chief Operating Officer; Chief Executive Officer; Chair of the Board of Directors; and External Auditors.

3. Section 5 of ILF Scotland’s Whistleblowing Policy relates to Confidentiality. This states: We hope that staff will feel able to voice whistleblowing concerns openly under this policy. However, if you want to raise your concern confidentially, we will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you. We do not encourage staff to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible and have been made in the public interest. Whistleblowers who are concerned about possible reprisals if their identity is revealed should come forward to the Chief Operating Officer, Chief Executive or Chair and appropriate measures can then be taken to preserve confidentiality. If you are in any doubt, you can seek advice from Public Concern at Work, the independent whistleblowing charity, who offer a confidential helpline. Their contact details are at the end of this policy.

4. Section 9 of ILF Scotland’s Whistleblowing Policy relates to Protection and Support for Whistleblowers. This states: It is understandable that whistleblowers are sometimes worried about possible repercussions. We aim to encourage openness and will support staff who raise genuine concerns in the public interest under this policy, even if they turn out to be mistaken. Staff must not suffer any detrimental treatment as a result of raising a concern in the public interest. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Chief Operating Officer, Chief Executive or Chair of the Board immediately. If the matter is not remedied you should raise it formally using our Grievance Procedure. Staff must not threaten or retaliate against whistleblowers in any way. Anyone involved in such conduct will be subject to disciplinary action.

5. (a) Henderson Loggie.
(b) October 2024.
(c) Please refer to Appendix 1.

Appendices

Appendix 1 - Equalities and Diversity Report - 20241002.pdf

Freedom of Information (FOI) Request

Reference Number:

FOI-170726

Fulfilment Date:

22/07/2026

Topic:

Employee Headcount

Request:

1. Please provide any correspondence, including letters, e-mails, or app messages, from your SG sponsor team, Ministers, or other SG officials, directing your organisation to meet or not exceed a specified headcount, or to reduce headcount by a specified amount.
2. Please provide any correspondence similar to the above which does not specify a particular headcount but which provides other direction in terms of savings or efficiency expectations, e.g. to paybill.
3. Please provide the employee headcount your organisation is aiming to meet or maintain at or by 1 April 2027, outlining whether that number was set by SG or internally.
4. Does the number provided in response to question 3 represent individuals or Full Time Equivalent?
5. Is the number provided in response to question 3 inclusive or exclusive of staff on fixed term contracts, secondees, agency workers, and workers of other irregular status?
6. If available, please provide a breakdown of this headcount by grade.

Response:

1.Independent Living Fund Scotland holds correspondence from Scottish Government officials relating to a pay and workforce data collection exercise commissioned by Scottish Exchequer in June 2026. This correspondence refers to Scottish Government workforce planning assumptions and targets, including guidance that overall public sector non-frontline staffing should reduce by 4% per annum in support of the Public Service Reform workforce reduction target, and requests workforce forecasts from public bodies. This correspondence does not direct ILF Scotland to meet or maintain a specified headcount, nor does it direct ILF Scotland to reduce its headcount by a specified amount.

Subsequent correspondence between ILF Scotland and its Scottish Government sponsor team acknowledged that ILF Scotland's forecast workforce growth was primarily driven by re-opening of the Fund and development of the Coming Home programme, largely comprising frontline operational roles, and recognised that any efficiencies achieved by the organisation may be offset by the additional staffing required to deliver these new responsibilities.

(For further information, please refer to Appendices 1 to 18.)

2. ILF Scotland holds correspondence from June 2026 regarding a Scottish Government pay and workforce data collection exercise. The correspondence states that the collection was intended to inform policy advice supporting the Public Service Reform Strategy and the 2027 to 2028 Budget and notes that workforce forecasts should take account of the Scottish Government's published workforce reduction target. The guidance states that overall public sector non-frontline staffing should reduce by 4% per annum in support of the Public Service Reform workforce reduction target.

Subsequent correspondence from the sponsor team sought additional information regarding efficiencies and how ILF Scotland was contributing to the Public Service Reform agenda while forecasting workforce growth. ILF Scotland explained that forecast growth was primarily related to the re-opening of the Fund and development of the Coming Home programme, and highlighted planned efficiency measures, including the use of AI-assisted tools to improve productivity.

However, ILF Scotland has identified no correspondence from Ministers, the sponsor team or other Scottish Government officials setting a specific workforce reduction, efficiency saving or paybill reduction target for ILF Scotland.

(For further information, please refer to Appendices 1 to18.)

3. As part of the June 2026 Pay and Workforce Planning Return submitted to the Scottish Government, ILF Scotland forecast: 91 FTE for 2026 to 2027; and 95 FTE for 2027 to 2028. These figures were developed internally for workforce planning purposes and were submitted to the Scottish Government as indicative planning assumptions rather than targets. The covering email accompanying the return explained that the projected increase reflected anticipated requirements associated with the Coming Home / re-opening programme and that the figures should be treated as indicative because the programme was still being scoped. As the return provides annual average FTE forecasts rather than a headcount at a particular date, ILF Scotland does not hold a specific employee headcount target for 1 April 2027.

4. The figures reported in the workforce planning return represent Full Time Equivalent (FTE) staff.

5. The workforce forecasts relate to directly employed staff only. According to the guidance accompanying the return, this includes permanent employees and fixed-term. ILF Scotland employs permanent or fixed term employees at the time of this FOI return. 6. ILF Scotland does not hold a forecast workforce breakdown by grade at this point in time due to planned growth to support the new Coming Home programme.

6. ILF Scotland does not hold a forecast workforce breakdown by grade at this point in time due to planned growth to support the new Coming Home programme.

Appendices

FOI-170726 - Appendix 1 - 20250328 - Letter Received - Scottish Government.pdf

FOI-170726 - Appendix 2 - 20260617 - Email Sent - Scottish Government.pdf

FOI-170726 - Appendix 3 - 20260625 - Email Sent - Scottish Government.pdf

FOI-170726 - Appendix 4 - 202503 - Guidance Note.pdf

FOI-170726 - Appendix 5 - 202504 - Monthly Return.xlsx

FOI-170726 - Appendix 6 - 202505 - Monthly Return.xlsx

FOI-170726 - Appendix 7 - 202506 - Monthly Return.xlsx

FOI-170726 - Appendix 8 - 202507 - Monthly Return.xlsx

FOI-170726 - Appendix 9 - 202508 - Monthly Return.xlsx

FOI-170726 - Appendix 10 - 202509 - Monthly Return.xlsx

FOI-170726 - Appendix 11 - 202510 - Monthly Return.xlsx

FOI-170726 - Appendix 12 - 202511 - Monthly Return.xlsx

FOI-170726 - Appendix 13 - 202512 - Monthly Return.xlsx

FOI-170726 - Appendix 14 - 202601 - Monthly Return.xlsx

FOI-170726 - Appendix 15 - 202602 - Monthly Return.xlsx

FOI-170726 - Appendix 16 - 202603 - Monthly Return.xlsx

FOI-170726 - Appendix 17 - 202604- Monthly Return.xlsx

FOI-170726 - Appendix 18 - 202605 - Monthly Return.xlsx

Freedom of Information (FOI) Request

Reference Number:

FOI-110925

Fulfilment Date:

29/06/2026

Topic:

Payments in Excess of £25,000 Made Since April 2018

Request:

Please provide details of all payments in excess of £25,000 made since April 2018.

Response:

ILF Scotland’s payments with a value in excess of £25,000 for the period April 2018 to March 2026 are as follows:

Scottish Government, 25/05/2018, £80,265.01

Scottish Government, 14/09/2018, £26,921.68

Scottish Government, 26/10/2018, £69,242.06

Scottish Government, 22/02/2019, £54,603.60

Scottish Government, 03/05/2019, £36,865.25

Scottish Government, 29/05/2019, £36,865.25

KPMG LLP, 06/09/2019, £49,758.00

Scottish Government, 28/02/2020, £64,562.40

Scottish Government, 15/01/2021, £69,202.80

NHS - National Services Scotland, 12/02/2021, £27,364.80

Iris Limited, 09/07/2021, £42,739.88

Scottish Government, 26/07/2021, £43,971.50

NHS - National Services Scotland, 16/02/2022, £27,364.80

Ideagen Huddle Ltd, 30/03/2022, £28,800.00

Scottish Government, 06/04/2022, £40,881.59

Iris Limited, 22/04/2022, £30,880.27

Scottish Government, 25/07/2022, £35,310.00

Scottish Government, 07/10/2022, £25,016.35

NHS - National Services Scotland, 09/12/2022, £57,718.16

NHS - National Services Scotland, 26/09/2023, £28,514.40

Scottish Government, 22/12/2023, £26,081.90

Scottish Government, 20/03/2024, £30,431.38

Green Lemon Company, 10/04/2024, £37,260.00

Green Lemon Company, 08/05/2024, £44,190.00

Green Lemon Company, 12/06/2024, £44,640.00

Scottish Government, 03/07/2024, £30,273.90

Green Lemon Company, 10/07/2024, £50,520.00

Green Lemon Company, 21/08/2024, £43,320.00

Green Lemon Company, 02/10/2024, £54,427.78

Green Lemon Company, 16/10/2024, £63,079.30

Scottish Government, 25/10/2024, £31,583.03

Green Lemon Company, 20/11/2024, £63,979.54

Green Lemon Company, 18/12/2024, £62,689.15

Scottish Government, 08/01/2025, £30,072.64

Computacenter, 08/01/2025, £49,560.76

Green Lemon Company, 05/02/2025, £67,018.44

Green Lemon Company, 19/02/2025, £61,193.18

Green Lemon Company, 12/03/2025, £43,380.00

Computacenter, 09/04/2025, £39,648.62

Green Lemon Company, 15/04/2025, £73,570.68

Scottish Government, 30/04/2025, £29,807.95

Green Lemon Company, 15/05/2025, £99,722.88

Green Lemon Company, 11/06/2025, £41,874.84

Green Lemon Company, 18/07/2025, £48,890.52

Green Lemon Company, 06/08/2025, £72,067.32

Scottish Government, 06/08/2025, £33,565.55

Green Lemon Company, 10/09/2025, £77,078.52

Green Lemon Company, 08/10/2025, £71,190.36

Scottish Government, 15/10/2025, £33,418.16

Green Lemon Company, 05/11/2025, £107,928.70

Scottish Government, 12/11/2025, £41,388.64

Green Lemon Company, 10/12/2025, £89,640.00

Green Lemon Company, 07/01/2026, £72,599.76

Scottish Government, 21/01/2026, £41,915.63

Computacenter, 29/01/2026, £111,390.56

Green Lemon Company, 04/02/2026, £83,248.56

Green Lemon Company, 04/03/2026, £79,803.36

Freedom of Information (FOI) Request

Reference Number:

FOI-010526

Fulfilment Date:

06/05/2026

Topic:

Recipients of the Transition Fund and Independent Living Fund

Request:

1) How many people received funding from both the Transition Fund and Independent Living Fund prior to 01/01/24?

2) How many people have received funding from both the Transition Fund and Independent Living Fund since 01/01/24?

Response:

1) No individuals received funding from both the Transition Fund and Independent Living Fund prior to 01/01/24.

2) 29 people have received funding from both the Transition Fund and Independent Living Fund between 01/01/24 and 06/05/26.

Freedom of Information (FOI) Request

Reference Number:

FOI-220426

Fulfilment Date:

01/05/2026

Topic:

Transition Fund

Request:

Please provide evidence to show that no individual has received multiple Transition Fund awards since new protocols were put in place on 1 January 2024.

Response:

ILF Scotland paid a total number of 4,092 Transition Fund grants between 1 January 2024 and 24 April 2026. All of these awards were paid to Recipients who had never before been in receipt of a Transition Fund award.

We received a total of 287 applications to the Transition Fund between 1 January 2024 and 24 April 2026 that were unsuccessful due to the fact that the applicant had previously been in receipt of a Transition Fund award.

This has been routine practice since we made the policy change on 1 January 2024 to preclude the award of more than one Transition Fund grant to an individual.

Freedom of Information (FOI) Request

Reference Number:

FOI-060226

Fulfilment Date:

17/02/2026

Topic:

The fulfilment of ILF Scotland’s legal obligations according to the Equality Act (2010) and Public Sector Equality Duty, the use of terminology in ILF Scotland publications and the capturing of data relating to sex and gender.

Request:

1) How is your organisation able to carry out its duties under the Equality Act to women as you state your organisation ‘has no formal definition of the word’? Specifically, how does your organisation meet its legal requirements to the Public Sector Equality Duty (PSED)?

2) How is your organisation meeting its legal duty to those of the protected characteristics of sex and sexual orientation, both in the general and Scottish specific duties (SSD) including a duty to assess the equality impact of proposed and revised policies and practices, and to publish the assessment if it ‘has no formal definition of the word “woman” and it ‘has no formal definition of the terms “lesbian”, “bisexual” and “gay’’’?

Please note specifically the following EQIA: Policy 24 - Statutory Input to ILF Scotland Funding on page 3:

‘Sex: Yes
Comments: The vast majority of unpaid carers are women so this policy change helps to address the disproportionate expectations placed by social pressures on women, which can impact on their ability to secure paid employment or enjoy retirement/social lives/personal wellbeing.’

3) Please can you explain what the word ‘women’ denotes, given your organisation has no formal definition of the word? Please note specifically the following from your Annual-Report-and-Accounts-Year-Ended-31-March-2025:

4) What does the term ‘gender’ denote here?

5) How does your organisation propose to capture data about the number of men and women it employs if it ‘has no formal definition of the word “woman’’’?

6) How was this information captured?

7) How was a conflation of sex and gender avoided in the construction of the question?

Response:

ILF Scotland does not create or use its own definition of protected characteristics. In line with other Scottish public authorities, ILF Scotland applies the statutory definitions set out in the Equality Act (2010), together with any relevant Scottish Government guidance that interprets those definitions. There is no requirement that ILF create or adopt their own ‘formal’ definition or interpretation of the word ‘woman’ and as is consistent with all other public bodies, ILF have adopted the statutory definition as set out in the Equality Act (2010).

ILF Scotland’s position is as follows:

• ILF Scotland does not issue internal, alternative, or supplementary definitions for statutory terms such as sex, woman, or man.

• ILF Scotland operates on the basis that protected characteristics are defined solely by the Equality Act (2010) and any legally binding judgments that clarify those definitions.

• Where staff provide information relating to their sex or sexual orientation—for example through HR, payroll, or equality monitoring forms—ILF Scotland records this as self-identified data, unless a statutory requirement specifies that another approach must be taken.

This reflects the standard practice across public bodies in Scotland when applying equality legislation.

ILF Scotland meets its Public Sector Equality Duty (PSED) by:

• applying the statutory definitions contained in the Equality Act (2010).

• completing Equality Impact Assessments (EQIAs).

• monitoring outcomes for people with protected characteristics using self-reported information (eHR system).

• ensuring that staff and managers follow ILF Scotland’s equality policies and complete mandatory equality training.

2) ILF Scotland does not create or use its own definition of protected characteristics. In line with other Scottish public authorities, ILF Scotland applies the statutory definitions set out in the Equality Act (2010), together with any relevant Scottish Government guidance that interprets those definitions. There is no requirement that ILF create or adopt their own ‘formal’ definition or interpretation of the words ‘woman’, ‘lesbian’, ‘bisexual’ or ‘gay’, and as consistent with all other public bodies, ILF have adopted the statutory definition as set out in the Equality Act (2010).

ILF Scotland meets both the general duty and the Scottish specific duties through the following approach:

Equality Impact Assessments (EQIAs)

• Completing EQIAs for proposed and revised policies.

• Publishing EQIAs as required under the Specific Duties Scotland (SDS).

• Using the statutory list of protected characteristics as defined in the Equality Act (2010).

• Considering potential impacts on sex and sexual orientation using self-identified information from staff and applicants.

Policies and Practices

• Reviewing new or updated policies for any potential impacts on protected groups.

• Including sex and sexual orientation as standard categories within the EQIA template.

Monitoring

• Using workforce monitoring categories that are consistent with those used across Scottish public authorities.

• Recording sex exactly as provided by the individual where this is required for payroll, HMRC or other statutory purposes.

• Recording gender based on the person’s self-identified gender, if stated. ILF Scotland does not apply any internal definition of gender beyond self-identification for monitoring purposes.

The EQIA for Policy 24 uses the term ‘women’ in line with the statutory protected characteristic of ‘sex’ as listed in the Equality Act (2010).

3) ILF Scotland does not create or use its own definition of protected characteristics. In line with other Scottish public authorities, ILF Scotland applies the statutory definitions set out in the Equality Act (2010), together with any relevant Scottish Government guidance that interprets those definitions.

Following the UK Supreme Court judgment in For Women Scotland v Scottish Ministers, the Court confirmed that under the Equality Act (2010), the terms ‘woman’, ‘man’, and ‘sex’ all refer to biological sex. The Supreme Court unanimously held that:

• The words ‘woman’ and ‘sex’ in the Equality Act (2010) must be interpreted as referring to a biological woman and biological sex.

4) ILF Scotland does not create or use its own legal definition of gender, and uses the term in line with the Scottish Government National Performance Framework interpretation and definition of sex and gender. This information can be viewed online at National Indicators by sex and gender | National Performance Framework.

5) HR and payroll data are collected in the following way:

• The category ‘sex’ is taken directly from the standard HMRC employee starter forms. These forms require individuals to provide their sex for payroll and tax purposes, and ILF Scotland records this information exactly as it is supplied by the employee.

• ILF Scotland does not apply any organisational definition of ‘woman’ or ‘man’; the information is accepted as stated by the individual. This approach ensures ILF Scotland meets its statutory payroll obligations while also supporting reporting requirements under the Equality Act.

6) Sex and gender information is captured through:

• HMRC starter forms, which require disclosure of sex for payroll and taxation (e.g., Starter Checklist).

• eHR forms, where individuals self-identify their gender and other protected characteristics.

7) ILF Scotland manages these categories separately to avoid any unintended conflation. Where relevant, two distinct fields are used:

• ‘Sex’ – recorded exactly as stated by the employee and used only where required for statutory or payroll purposes.

• ‘Gender’ – the individual’s self-identified gender, used for internal monitoring purposes.

• Within Equality Impact Assessments and equality duty reporting, ILF Scotland applies the statutory protected characteristic of sex.