ILF Scotland is committed to providing high-quality customer services.
We value complaints and use information from them to help us improve our services
If something goes wrong or you are dissatisfied with our services, please tell us. This leaflet describes our complaints procedure and how to make a complaint. It also tells you about how we will handle your complaint and what you can expect from us.
What is a complaint?
We regard a complaint as any expression of dissatisfaction about our action or lack of action, or about the standard of service provided by us or on our behalf.
What can I complain about?
You can complain about things like:
failure or refusal to provide a service
inadequate quality or standard of service, or an unreasonable delay in providing a service
dissatisfaction with one of our policies or its impact on the individual
failure to properly apply law, procedure or guidance when delivering services
failure to follow the appropriate administrative process
conduct, treatment by or attitude of a member of staff
disagreement with a decision, (except where there is a statutory procedure for challenging that decision, or an established appeals process followed throughout the sector).
Your complaint may involve more than one ILF Scotland service or be about someone working on our behalf.
What can’t I complain about?
There are some things we can’t deal with through our complaints handling procedure. These include:
a routine first-time request for a service
a request for compensation only
issues that are in court or have already been heard by a court or a tribunal (if you decide to take legal action, you should let us know as the complaint cannot then be considered under this process)
disagreement with a decision where there is a statutory procedure for challenging that decision (such as for freedom of information and subject access requests), or an established appeals process followed throughout the sector
a request for information under the Data Protection or Freedom of Information (Scotland) Acts
a grievance by a staff member or a grievance relating to employment or staff recruitment
a concern raised internally by a member of staff (which was not about a service they received, such as a whistleblowing concern)
a concern about a child or an adult’s safety
an attempt to reopen a previously concluded complaint or to have a complaint reconsidered where we have already given our final decision
abuse or unsubstantiated allegations about our organisation or staff; or
a concern about the actions or service of a different organisation, where we have no involvement in the issue (except where the other organisation is delivering services on our behalf).
If other procedures or rights of appeal can help you resolve your concerns, we will give information and advice to help you.
Who can complain?
Anyone who receives, requests or is directly affected by our services can make a complaint to us. This includes the representative of someone who is dissatisfied with our service (for example, a relative, friend, advocate or adviser). If you are making a complaint on someone else’s behalf, you will normally need their written consent. Please also read the section on Getting help to make your complaint below.
Child Friendly Complaints
As outlined in Who can complain? above, anyone who receives, requests or is directly affected by our services can make a complaint.
On occasion this may refer to a young person who is aged under 18 and therefore defined as a child.
If ILF Scotland receives a complaint from a person aged under 18, or a person complaining on their behalf, we will ensure that we handle any such complaint affecting any child in a way that meets all of their rights under UNCRC (United Nations Convention on the Rights of the Child).
ILF will keep the best interests of the child as a top priority in all decisions and actions that affect them (UNCRC Article 3).
The SPSO has created guidance for Child Friendly Complaints that ILF Scotland will refer to when handling complaints from any individual under 18 years. Further information on this guidance can be found at:
You can complain in person at our offices, by phone, in writing or by email using the contact details below.
It is easier for us to address complaints if you make them quickly and directly to the service concerned. So please talk to a member of our staff at the service you are complaining about. Then they can try to resolve the issue.
Normally, you must make your complaint within six months of the event you want to complain about or finding out that you have a reason to complain.
In exceptional circumstances, we may be able to accept a complaint after the time limit. If you feel that the time limit should not apply to your complaint, please tell us why.
What happens when I have complained?
We will always tell you who is dealing with your complaint. Our complaints procedure has two stages.
Stage one: Frontline response
We aim to respond to complaints quickly (where possible, when you first tell us about the issue). This could mean an on-the-spot apology and explanation if something has clearly gone wrong, or immediate action to resolve the problem.
We will give you our decision at stage one in five working days or less, unless there are exceptional circumstances.
If you are not satisfied with the response we give at this stage, we will tell you what you can do next. If you choose to, you can take your complaint to stage two. You must normally ask us to consider your complaint at stage two either:
within six months of the event you want to complain about or finding out that you have a reason to complain or
within two months of receiving your stage one response (if this is later).
In exceptional circumstances, we may be able to accept a stage two complaint after the time limit. If you feel that the time limit should not apply to your complaint, please tell us why.
Stage two: investigation
Stage two deals with two types of complaint: where the customer remains dissatisfied after stage one and those that clearly require investigation, and so are handled directly at this stage. If you do not wish your complaint to be handled at stage one, you can ask us to handle it at stage two instead.
When using stage two:
we will acknowledge receipt of your complaint within three working days
we will confirm our understanding of the complaint we will investigate and what outcome you are looking for
we will try to resolve your complaint where we can (in some cases we may suggest using an alternative complaint resolution approach, such as mediation) and
where we cannot resolve your complaint, we will give you a full response as soon as possible, normally within 20 working days.
If our investigation will take longer than 20 working days, we will tell you. We will tell you our revised time limits and keep you updated on progress.
What if I’m still dissatisfied?
After we have given you our final decision, if you are still dissatisfied with our decision or the way we dealt with your complaint, you can ask the Scottish Public Services Ombudsman (SPSO) / Northern Ireland Public Services Ombudsman (NIPSO) to look at it.
The SPSO / NIPSO are independent organisations that investigate complaints. You can ask the SPSO / NIPSO to look at your complaint if:
you have gone all the way through ILF Scotland’s complaints handling procedure
it is less than 12 months after you became aware of the matter you want to complain about; and
the matter has not been (and is not being) considered in court.
We understand that you may be unable or reluctant to make a complaint yourself. We accept complaints from the representative of a person who is dissatisfied with our service. We can take complaints from a friend, relative, or an advocate, if you have given them your consent to complain for you.
You may wish to get independent support or advocacy to help you progress your complaint. You can find out about advocates in your area by contacting the Scottish Independent Advocacy Alliance, tel: 0131 510 9410, website: www.siaa.org.uk.
You can find out about advisers in your area through Citizens Advice Scotland, website: www.cas.org.uk or check your phone book for your local citizens advice bureau.
We are committed to making our service easy to use for all members of the community. In line with our statutory equalities’ duties, we will always ensure that reasonable adjustments are made to help you access and use our services. If you have trouble putting your complaint in writing, or want this information in another language or format, such as large font, or Braille, please tell us in person, contact us on 0300 200 2022 or email us on enquiries@ilf.scot.
Quick guide to our complaints procedure
Complaints procedure
You can make your complaint in person, by phone, by email or in writing. We will always try to deal with your complaint quickly. But if we think we need to investigate, we will tell you and update you on our progress.
We have a two-stage complaints procedure.
Stage One: Frontline response
We will respond to your complaint within five working days if we can.
If you are dissatisfied with our response, you can ask us to consider your complaint at stage two.
Stage Two: Investigation
We will look at your complaint at this stage if you are dissatisfied with our response at stage one. Or if it is clear that we need to investigate.
We will acknowledge your complaint within three working days.
We will investigate the complaint and give you our decision as soon as possible but within 20 working daysunless we need more time.
Public Services Ombudsman
If you remain dissatisfied with our final decision or about the way we have handled your complaint, you can ask the SPSO or the NIPSO to consider our handling of your complaint.
ILF Scotland is a company limited by guarantee, registered in Scotland, Company Number: SC500075. Registered office: Denholm House, Almondvale Business Park, Almondvale Way, Livingston, EH54 6GA
Mainstreaming and Equality Outcomes Report - 2026 to 2028
Foreword
We are pleased to introduce our fourth Mainstreaming and Equality Outcomes Report. This document highlights the progress we have made in delivering our 2024 to 2026 equality outcomes and sets out our equality outcomes for 2026 to 2028 and the actions we will take to achieve them.
We aim to review our progress and planning relating to equality regularly and, as a minimum, to conduct a formal appraisal of our activities including our progress in achieving our mainstreaming equality objectives, on an annual basis.
We introduce this report after successfully operating the re-opened Independent Living Fund in Scotland for two years. Since April 2024, we have received over 1,400 applications and provided funding of £9.7 million, enabling many more disabled people with the most complex needs to access the support they need to live independent lives within their chosen communities.
Equality is at the heart of what we do as an organisation and runs through all our everyday activities, thoughts, behaviours and plans. We strive to continuously improve on our commitment to mainstreaming equality across the organisation.
Our Board and staff group are diverse with regards to their own lived experience and they are also well-informed about equality, diversity and inclusion more broadly. We continue to listen to and learn from disabled people and strive to provide better-informed services relating to equality, diversity and inclusion to our Recipients, our staff and our other key stakeholders. The organisation does not operate in isolation and we continue to seek out best practice, obtain feedback on our services, consider reporting tools and be involved in partnership working.
Our key focus on addressing inequality is in relation to protected characteristics but we are also considerate of broader definitions of diversity that focus on additional areas. This last year, for example, we have had a greater focus on neurodiversity, cognitive diversity, social mobility and socio-economic diversity. We realise the importance of considering the intersectionality and the impact of how a combination or more than one protected characteristic can perpetuate different forms of discrimination or inclusion challenges.
Our plans are informed by a consideration of the existing context, as well as anticipated future impacts, such as the increase in the use of AI technologies, increased regulatory interest in identifying meaningful diversity metrics, the Scottish Government’s revisions to the National Performance Framework, and the introduction of the Human Rights Bill. We also look to incorporate best practice and guidance such as the UK Government’s Disability Action Plan.
We operate a discretionary fund providing ongoing awards to just under 4,000 disabled people in Scotland and Northern Ireland to help them live independently with choice, control and dignity in their own homes and within their local communities.
In addition, we provide one-off grants via our Transition Fund for young disabled people in Scotland aged 16 to 25 to help them increase their independence and participate in their communities. Between 2024 and 2026 we provided grants to just under 5,000 young disabled people.
Our Staff
ILF Scotland employs 80 people – 3 on temporary contracts. Of those, 3 members of staff are based in Northern Ireland and 77 work across Scotland. 53 of these are support staff based in the Livingston office and 27 are home-based assessors. We actively recruit colleagues who are disabled and who have long-term health conditions. We are a close team and we regularly listen to what staff have to say both informally and using regular survey tools. On our website there are two case studies from members of our staff to hear from them directly.
Legal Framework
The Equality Act 2010 sets out the general equality duty for all public authorities to have due regard to the need to:
eliminate unlawful discrimination, harassment, and victimisation and other prohibited conduct
advance equality of opportunity between people who share a relevant protected characteristic and those who do not, particularly by removing or minimising disadvantage; meeting the needs of particular groups that are different from the needs of others; and encouraging participation in public life
foster good relations between people who share a protected characteristic and those who do not
The Equality Act 2010 lists nine protected characteristics:
Age
Disability
Gender Reassignment
Marriage and Civil Partnership
Pregnancy and Maternity
Race
Religion or Belief
Sex
Sexual Orientation
and defines direct and indirect discrimination as:
“Where someone is treated less favourably according to a protected characteristic or could be disadvantaged compared to someone who does not share that protected characteristic.”
All people are entitled to equal treatment and the way in which people are treated shapes their lives and lived experiences. We recognise and understand how unequal treatment under each characteristic impacts people, particularly those who are living with more than one or multiple protected characteristics.
ILF Scotland must comply with the Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012 and the specific duties designed to help Scottish public authorities meet the general duty. Regulation 4 of the specific equality duties requires that we base our Equality Outcomes on evidence and involvement of equality groups.
ILF Scotland is required to report on the areas outlined below every two years, apart from the Statement on Equal Pay, which is every four years. We also have a duty to publish diversity information about our board members. This report meets our general and specific duties under the Equality Act 2010 and outlines:
Mainstreaming equality is a long-term, strategic approach to ensure that equality, diversity and inclusion is truly integrated and sits at the heart of organisational culture, strategic planning and operational delivery.
This ambition is evolving and ongoing and we have the commitment, encouragement and support of our Board and our Senior Leadership Team (SLT) to deliver on this. We aim to make sure that every member of our staff team understands, accepts and embraces equality across every part of our organisation and in the services we deliver to our Recipients. We believe that mainstreaming equality has many benefits including helping us to:
put equality at the heart of everything we do
embrace diversity across our organisation and attract and retain a motivated workforce, rich in talent, skills and experiences
continually improve our service delivery and make sure our services meet the diverse needs of our Recipients
help us to be more socially inclusive and engage better with those most excluded in society
We strongly embrace the principles of equality and are proud of the journey we have taken so far.
We became a Non-Departmental Public Body (NDPB) in 2018 and since then there have been changes to the wider equality context in which we work. These include legislative changes, the impact of major events and societal changes bringing certain inequalities into the foreground. Key recent examples to note include:
Legislation Milestones:
The United Nations Convention on the Rights of the Child (UNCRC) came into effect in July 2024. The UNCRC aims to ensure that the rights of children are upheld and that their views are taken into account in decisions that affect them including policy, practice and budget-making decisions. As a public body, ILF Scotland is required to report on our implementation and progress towards compliance as at the end of March 2026. We plan to publish our child friendly statement and plan within the first quarter of 2026 to 2027. As part of ensuring compliance with the UNCRC, we have:
Added a UNCRC page to our website with links to Scottish Government videos and information and ILF commitment to the Act.
Publicised information in our Recipient newsletters and discussed with our Scotland and Northern Ireland Advisory Groups and our Young Ambassador Groups.
Raised awareness of the legislation and our duties and requirements, promoting children’s rights throughout the organisation from our Board to our front-line staff. We are including the online Scottish Government e-learning course, Introduction to Children’s Rights, as a training course for all staff and incorporating it in our induction material for all new staff. Relevant staff will participate in more targeted training courses to be delivered by an external trainer later in the year. Additionally, we will incorporate elements into our existing EQIA, corporate parenting and child protection training courses.
Revised our published complaints process to ensure it is relevant and accessible to children and young people and we are committing to review all our other publications to ensure the material on our website, newsletters, leaflets, correspondence, etc. is child friendly and accessible.
As part of encouraging participation and empowerment of children and young people and ensuring that young people have a voice, we are reviewing and developing a relaunch of our Young Ambassador Group to include Recipients of our re-opened fund, should they wish to join. As part of this exploratory work to ensure we take the views of young people on board, we are liaising with the members of the UNCRC peer group to share best practice and exploring involvement with other relevant, and already established, youth groups.
Incorporated Wellbeing Impact Assessments (CRWIA) in to our existing Equality Impact Assessments.
From 1 April 2025, changes to the Disclosure (Scotland) Act 2020 – Protection of Vulnerable Groups mean that people working in a regulated role must register to become a member of the PVG scheme. This impacted on our disabled Recipients, primarily in relation to our main Independent Living Fund but also our re-opened ILF in 2024.
We published information and individually advised our Recipients of this change ensuring they understood the legal requirement for any Personal Assistants (PAs) who support them, to join the PVG scheme. We confirmed that the legal onus is on the PA not the recipient to join the scheme and that it would be a criminal offence for their PA to continue to support them in paid work if they do not have a PVG membership.
ILF Scotland is considered a relevant public authority under the Consumer Scotland Act 2020 (relevant public authorities) Regulations 2024. This requirement came into effect on 1 April 2025 and places a statutory duty on us as a public body, when making decisions of a strategic nature, to have regard to the impact of those decisions on consumers in Scotland and the desirability of reducing harm to those consumers.
This requirement will be introduced by ILF Scotland formally on 1 April 2026. Guidance from Consumer Scotland recommends the use of an impact assessment and has provided a template incorporating the Consumer Duty Assessment with the Equality Impact Assessment and other statutory impact assessments. ILF Scotland staff members are currently considering the best way to incorporate everything we need in the one impact assessment process, where possible, as part of an overarching Equality Impact Assessment Process with a view to implementing this after appropriate training in 2026 to 2027.
We have met some of the requirements of the 2020 Act during the financial year 2025 to 2026, specifically ensuring we actively consider the impact of our strategic decisions on consumers and having regard to the desirability of reducing harm. For example, we co-produced our 2025 to 2028 strategy with disabled people and their representative and supporting organisations, resulting in a strategy that puts disabled people at the heart of everything we do, leading to improved independent living outcomes that are important to consumers – our Recipients.
We have not, however, met all of the requirements of the 2020 Act during this period. We are currently broadening our Equality Impact Assessment process and we will now include the recommended Consumer Duty Impact Assessment as part of this, which should allow us to confirm full compliance with the duty in next year’s report.
The introduction of the Employment Rights Act (2025) brings important changes to equality and fair work, enhancing protections for employees and reinforcing employers’ responsibilities to create safe, inclusive and supportive working environments, including strengthened duties to prevent and address sexual harassment.
Ongoing debate and legal action to clarify the definition of sex in law and attempts to reform the Gender Recognition Act in Scotland in 2023 has increased awareness of the experiences of transgender people. As a public body, we await guidance on any required changes to policy following the recent court ruling on gender.
The Scottish Government has now committed to introducing a new Human Rights Bill for Scotland. This will incorporate, within the competencies of devolution, the United Nations (UN) human rights treaties of:
International Covenant on Economic, Social and Cultural Rights (ICESCR)
Convention on the Elimination of All Forms of Discrimination against Women (CEDAW)
International Convention on the Elimination of All Forms of Racial Discrimination (CERD)
Convention on the Rights of Persons with Disabilities (CRPD)
The new Bill will also include the right to a healthy environment, as well as rights for older people and LGBTQI+, which includes lesbian, gay, bisexual, transgender, queer (or questioning) and intersex people.
Following the implementation of the Hate Crime and Public Order (Scotland) Act 2021, the Scottish Government is actively consulting on adding sex as a protected characteristic to this Act to specifically address misogynistic harassment, with reports on this activity released in early 2026.
The Scottish Government is working on the Learning Disabilities, Autism and Neurodiversity Bill, with a partial Equality Impact Assessment published in March 2026.
Key Events and Societal Changes
The COVID-19 pandemic drew further attention to societal inequalities with women, disabled people and ethnic minority groups disproportionately impacted by the effects of the virus and of lockdown measures and we continue to see the effects of this. The pandemic has also changed the way we work and live, with more homeworking and reliance on digital technologies.
Population growth in Scotland continues to be driven by international migration and migration from elsewhere in the UK, together with changes in birth and death rates.
The ongoing cost of living crisis continues to intensify, driven in part by rising inflationary pressures linked to the conflicts in Iran and Ukraine. These pressures are widening existing inequalities and increasing levels of poverty, with disabled people disproportionately affected due to higher living costs related to disability, greater reliance on fixed incomes, and reduced access to secure employment.
Recent events in global media have highlighted the serious impact of persisting inequalities related to gender, socio economic disadvantage, and power. Evidence across the UK, including in Scotland and Northern Ireland, demonstrates that these risks can arise across a range of different settings including in private family life, and that exploitation continues across workplaces and communities when vulnerability and power imbalances are not adequately challenged and addressed.
Research indicates that misogyny is deeply ingrained in Scotland’s social and patriarchal structure, with minority groups of women facing higher risks. Women are not adequately protected and current misogynistic behaviour is widespread.
All of the above informs our thinking and our statutory responsibility under the Public Sector Equality Duty. These societal issues highlight the importance of us mainstreaming equality outcomes across policy development, decision making, service delivery, and review and this reports provides us with a vehicle to demonstrate progress in advancing equality and reducing unequal outcomes where we can.
Our Recipients
The Recipients of our funds are disabled people. We have two funds, the Independent Living Fund, which re-opened to applicants in April 2024, and the Transition Fund.
Our funding helps our Recipients to access the same opportunities as others and achieve their personal independent living outcomes. We continuously review our strategies, plans, policies and practice to provide the best service we can.
Here you can find out more about our work from some of our Recipients:
As part of ILF Scotland’s ethos and aim to work in co-production with our Recipients, we meet regularly with members of the ILF Scotland and Northern Ireland Advisory Groups.
The purpose of these Groups is to support the improvement and development of ILF Scotland for Recipients living in Scotland and Northern Ireland, by advising on all matters relating to the operation of the fund, including:
experiences of using the existing fund
experiences of communicating and interacting with ILF Scotland
insight and advice into potential policy developments relating to the existing fund
content and accessibility of ILF Scotland publications
any other relevant matters
The Advisory Groups report to the ILF Scotland SLT, who in turn report learning and outcomes from the Group to the Board and the Scottish Government, as required.
The Groups meet quarterly on an individual basis and meet jointly three times each year with additional occasions meetings with the Minister of Social Care and Wellbeing in Scotland, the Minister for Health in Northern Ireland and with ILF Scotland’s Board members and staff.
The minutes from the Group meetings are available on our website.
We engage with our Recipients in a variety of other ways:
We re-opened ILF in April 2024 with a policy framework co-produced with our Recipients and their supporters and other key stakeholders following a series of in person engagement events at venues across Scotland complimented by online engagement meetings. We have since collected Recipient feedback about the re-opened fund and published this on our website. Overall, the feedback captured demonstrates a high level of satisfaction with the funding awarded and with people’s interaction with ILF Scotland:
88% indicated their independent living outcomes were achieved
95% indicated the funding had a significant impact on their lives
94% indicated they were very satisfied with both the application process and their visit by one of our Assessors
Between 2024 and 2026 members of staff attended more than 100 events with over 2,000 attendees, organised by partner organisations to present or to manage a stall to raise awareness and provide information about the Independent Living Fund and in the majority of occasions, the Transition Fund. A significant amount of this engagement takes place in schools, at transition events and with parent groups. These sessions also regularly involve young people who are care-experienced, supported by social work transitions teams, Looked After and Corporate Parenting staff, or school-based Additional Support Needs leads. We have, in addition, delivered workshops, guidance sessions and targeted outreach with a range of charitable, third, public and government sector organisations supporting young disabled people. This ensures that young people who require additional support, including those who are care-experienced, digitally excluded, or who have limited family resources and who are most at risk of missing out, find out about the possibility of funding from ILF Scotland.
We celebrated ILF Scotland’s 10th birthday by holding events for our Recipients and their representatives and supporters in Scotland and Northern Ireland in June and July 2025. Speeches were delivered from advocates of disability and human rights, and people shared inspiring stories about how ILF Scotland helped them live with choice, dignity and independence. Our website provides further information, including videos and photographs about the events. Both events were a success and feedback from attendees demonstrated how impactful attendees felt the events were and provided helpful information on accessibility needs, the difference the funding makes in people’s lives and suggestions for improvements at future events. We produced a summary of feedback from attendees of both events which is available on our website.
Equality Impact Assessment
We carry out Equality Impact Assessments (EQIAs) when we develop our external policies and publish these on our website. In addition, we conduct screening exercises for all internal policies and produce EQIAs where required. We have incorporated early consideration of Equality Impact Assessments as part of our internal project planning tools and continue to work to extend EQIAs across all our service delivery areas to cover all relevant decision making that affects people with protected characteristics.
We have incorporated Care Experienced young people in our Equality Impact screening and EQIAs, and in the next financial year, we intend to include poverty and rurality as well, because of the effect of these conditions on disabled people.
ILF Scotland is a public authority required to comply with the Consumer Duty, the guidance on which includes a template incorporating the Consumer Duty Assessment with the Equality Impact Assessment and other statutory impact assessments. ILF Scotland staff members are currently considering the best way to incorporate everything we need in the one assessment process, where possible with a view to implementing this after appropriate training in 2026 to 2027.
We believe in the many advantages of conducting EQIAs, in addition to adhering to our statutory duty to do so, including:
enshrining the rights of disabled people to being treated with dignity and respect and being able to exercise choice and control in living their lives
systematically conducting EQIAs early in the planning process ensures that we identify any barriers that we need to avoid or mitigate as part of our decision-making
going through the EQIA process makes sure that we think about how the consequences of our plans and decisions might affect people with protected characteristics, other than disability, ensuring that different groups are included
ensuring that we gather relevant information to demonstrate that our decisions are based on evidence, which is important in the event of challenge
We raised awareness and provided training across the organisation of our Equality Impact Assessment tool and screening assessment plan, taking staff through relevant worked examples of EQIAs on live work-related topics during 2024 to 2025 and 2025 to 2026. We will repeat this training in 2026 to 2027 along with additional worked examples to embed this area further in future, which will enable us to apply good equality practice across the organisation.
Key partners in our approach to equality include the Scottish Government and the Non-Departmental Public Body Human Resources network and forum where core Scottish Government and other Public Bodies share best practice on equality and diversity policy and practice.
In addition, we have developed ongoing positive working relationships with ARC Scotland, Who Cares? Scotland. This ensures that we keep equality at the heart of any decisions we make regarding the services we provide to young disabled people through our Transition Fund. We also signpost disabled people to other sources of support, such as the Scottish Welfare Fund and other charities, benefits agencies / advisory organisations as appropriate.
We also actively seek opportunities to engage with partners across the sector to support the mainstreaming of equalities, sharing learning and contributing to wider improvements in equality outcomes through our continued participation in events and stakeholder meetings.
We value the important input and feedback of our Advisory Group members in Scotland and Northern Ireland on equality when we work with them to develop the Charter for Involvement and through co-production on our strategies and policies.
We aim to adopt a human rights approach to all that we do and the Charter fits with human rights legislation, specifically the United Nations Convention on the Rights of Disabled Persons, supporting the realisation of Article 19 of the United Nations Convention on the Rights of Persons with Disabilities – “living independently and being included in the community”.
Implementing the Charter actions, co-produced by the Advisory Groups, helps ensure that we listen to our disabled Recipients and their representatives so that they remain at the heart of our decision-making.
We continue to embrace ways to work in partnership to improve our services and approach.
Report on Progress on Equality Outcomes for 2024
We set ourselves ambitious equality outcomes and these will be considered in the next section of this report.
Some of our Key Equality Achievements:
We re-opened the Independent Living Fund so that more disabled people could continue to live independently at home with a better quality of life.
We published our first feedback strategy and our feedback findings across various themes, which provided us with important learning.
We organised a variety of engagement events to celebrate and support independent living and also spoke at a variety of other organisations’ events to raise awareness of our funding and the difference it can make to disabled people.
We continued to work with our partners across Scottish and local government and the third and independent sectors to promote the provision of support to enable people to continue to live at home and achieve the independent living outcomes important to them.
Reviewed all of our fund policies to ensure they remain fit for purpose and offer as much flexibility as possible to allow disabled people to maximise their ILF awards or grants in the best way for them.
In June 2024, we were awarded Best Small Employer and in June 2025 we received the Best Practice Family Friendly Champion Award at the Working Families Best Practice Awards. We were also recognised as one of the Top 10 Working Families organisations in both 2024 and 2025
In 2025 we became the first employer in Scotland to be awarded the Gold Standard Kinship Friendly Employer accreditation. Gold standard support includes offering paid leave to all kinship carers, when they take on the care of a child, that equals the organisation’s adoption leave and pay.
In addition, we signed up to the Age Friendly and Dyslexia Friendly Employer pledges demonstrating the commitment and value of recognising and supporting staff. We also set up Neuro Minds, our staff neurodiversity group to raise awareness and celebrate neurodiversity at ILF Scotland.
Picture - Chris Watt Photography
Progress in Relation to Objectives set for 2024 to 2026
Our Equality Objectives were integrated into our business plan as Specific, Measurable, Achievable, Realistic and Timebound (SMART).
Outcome 1: Integrated Equality Impact Assessments
Integrated Impact Assessments are consistently applied across the organisation with a commitment to have our staff members appropriately trained and our board members fully aware of this.
Action: Further embed the use of Equality Impact Screening and Assessment practices across all business functions by providing additional awareness and practice training to Managers by the end of 2024 to 2025.
Update: We provided additional training to staff and managers in 2024 to 2025 and in 2025 to 2026. We have extended the automatic equality impact screening from our public policies to all of our internal policies and have incorporated this process into our project planning framework. During the next plan, we will continue to work to ensure all decisions about service development or changes to service delivery automatically incorporate equality impact screening and assessment where required.
Outcome 2: Promote Neuro-Inclusion
To start the neuro-inclusion journey within ILF Scotland focused on developing a neuro-inclusive culture with the aim of creating even greater comfort and belonging for our diverse staff group.
Action: We provided neurodiversity training to all staff in 2026 through The Donaldson Trust, raising awareness along with specialist training for our front-line staff so they can provide informed customer service to our Recipients who are neurodivergent, plus Leadership training for managers and Senior Leadership Team.
In 2025, we also created Neuro Minds, our staff neurodiversity group with the aim to create a workplace where everyone feels valued, fairly treated, supported and able to thrive. We celebrate the strengths and talents of neurodivergent people and work together to promote understanding, acceptance and meaningful inclusion.
Outcome 3: Corporate Parenting
More young disabled people who are Care Experienced are aware of the Transition Fund and how to apply, and our staff and Board members are aware of the Transition Fund and how it might positively impact Care Experienced young people.
Action: Through our Corporate Parenting Plan, we will further develop our communications strategy to target Care Experienced young people and those that support them to ensure they are aware of the Transition Fund. We will ensure ILF Scotland staff and Board Members are aware of the principles of Corporate Parenting through training courses and induction programmes.
As part of our commitment to advancing equality and supporting diverse family structures, ILF Scotland introduced a Kinship Care Policy in 2025. This policy mirrors the principles of our Maternity and Adoption policies by providing equitable support to employees who take on the primary care of a child through kinship arrangements. It recognises the vital role that family members and close connections play in providing stable, loving care, and ensures that kinship carers have access to protected leave, enhanced pay and flexible working options during this important time. The introduction of this policy reflects our ongoing commitment to fair work, inclusion and ensuring that all forms of caregiving are valued and supported within our organisation.
In 2025, we introduced a positive action recruitment measure to support applicants who are Care Experienced, aligned in approach to the principles of the Disability Confident scheme. When an applicant identifies as being Care Experience and meets all essential criteria outlined in the job description, they are guaranteed progression to the next stage of the recruitment process.
We are proud to collaborate with them to recognise, value and support kinship carers, relatives and friends who step up to raise a child when their parents are unable to. We have ensured all our Family Friendly policies include kinship carers: providing our managers with guidance to help them support kinship carers with flexibility and kindness and raising awareness of kinship care to our staff. We are also proud to be introducing kinship care leave on par with adoption leave.
In 2025 we were recognised by the leading national charity Kinship as Gold Standard Kinship Friendly Employer and the first employer In Scotland to achieve the accreditation.
Outcome 4: ILF Re-Opening
Following an announcement by the First Minister in September 2023, the Independent Living Fund, closed to new applications since 2010, re-opened to new applicants in April 2024. This enabled up to 1,000 additional disabled people with the most complex needs to access the support they need to live independent lives.
A Co-Production Working Group was established in October 2023, consisting of disabled people, carers, disabled people's organisations (DPOs) and representatives of ILF Scotland, the Scottish Government and health and social care statutory partners. A range of engagement events were held to seek views on the policy framework for the re-opened fund. A commitment was given to continue to develop policy in 2024 to 2025.
Action: Facilitate meetings of the Co-Production Working Group every two months in 2024 to 2025, with the first meeting to be scheduled for June 2024. Report on learning from the first two months of receiving applications to the re-opened fund and work together with the group and others as required to further develop policies around the key issues raised by disabled people and others at the re-opening engagement events. Arrange further co-production opportunities with our Recipients and others as part of our strategic planning consultations in the latter part of 2024 to 2025.
Update: The Co-Production Working Group continued to meet regularly during 2024 to 2025 with the first of these meetings held in June 2024. Meetings continued during 2025 to 2026. ILF Scotland senior staff have worked closely with the Group to report on the operation of the re-opened fund, including the number of places allocated and taken up, challenges, learning and feedback. We received positive feedback and reported this back to the Group.
The Group recommended a policy change to include a Care Component. This would allow disabled people who did not currently meet the £800 local authority funding threshold for the re-opened fund, but who would have if account were to be taken of the significant amount of support provided to them by an unpaid carer residing with them. The Minister accepted this recommendation and ILF Scotland implemented a Carer Component in January 2025, which resulted in an additional 218 applications to the re-opened Fund.
During 2025 to 2026 we worked with the Group to develop a DPO supported pilot to test an alternative route to local authority applications, which will provide learning relevant to the consideration of a potential citizen led application route to the re-opened ILF. The pilot will last for 12 months from 2 April 2026 to 31 March 2027 and will be funded as part of the Scottish Government’s Disability Equality Plan. We ran a series of online and in-person events during 2024 to 2025 to co-produce our Strategic Plan 2025 to 2028 with our disabled Recipients and their supporters. They directly influenced our direction of travel through the articulation of aims and objectives important to the achievement of independent living outcomes.
Summary
We made strong progress in achieving the actions set out in our plan as part of our Mainstreaming and Equality Outcomes Report for 2024 to 2026.
We were unable, as planned, to undertake further work on our forms and systems to provide better equality data on protected characteristics across both funds to improve our monitoring and reporting practices in line with good practice. We will therefore carry this action forward to the next plan.
ILF Scotland remains committed to embedding equality outcomes and will pursue further expansion and improvement on our approach to working in partnership with others to promote equality in Scotland.
Board Diversity Duty
The Gender Representation on Public Boards (Scotland) Act 2018 sets an objective that public boards should have 50% of their non-executive members who are women.
ILF Scotland has worked proactively with the Scottish Government over a number of years to strengthen the diversity and gender balance of our Board. We have maintained more than 50% female representation on our non-executive Board since 2015 and have sustained this position through to 2024, with women making up 75% of Board members.
We regularly review the diversity and representativeness of our Board to ensure it reflects the communities we serve, and we recognise that people from ethnic minority backgrounds remain underrepresented. We have 9 Board members, 4 of whom identify as disabled. We will continue to take proactive steps to improve representation, working closely with the Public Appointments Team during future Board recruitment processes to promote wider participation and encourage applications from underrepresented groups. ILF Scotland also follows the Equality and Human Rights Commission’s good practice guidance How to Improve Board Diversity: Six Step Guide to support fair, transparent and inclusive appointment processes.
In 2023 there were 4 women and 3 men. In 2024 there were 6 women and 2 men. In 2025 there were 6 women and 1 man.
2023
2024
2025
Women
4
6
6
Men
3
2
1
Employee Information
Staff (Female / Male)
Female Employees: 77.58% Male Employees: 22.5%
Full and Part Time Female / Male
Female Full Time: 51.25% Male Full Time: 18.75% Female Part Time: 26.25% Male Part Time: 3.754%
Part time working patterns remain predominate toward women.
During 2024 to 2026, 100% of staff worked within our hybrid working offering, with employee choice and control over whether they were working in the office or at home.
We used data capture and analysis to measure the representativeness of our workforce profile and use this information to identify improvement measures such as targeted recruitment.
The accuracy of our equality profile data is important as it can assist our Board and SLT in planning the workforce of the future and provides for the potential justification of allowable positive action to make improvements, leading to a workforce that reflects the population and geographical locations we work in.
Our workforce monitoring data indicates that there is room for improvement in the representation of people from ethnic minority groups and LGBTQI+ colleagues within our workplace. Our organisational demography by the end of Q4 2025 to 2026 was 80 staff and 9 Directors.
Women are well represented in the general workforce and at managerial level: 77.5%:22.5% female: male. At Director and Senior Leadership Team level, however, women remain comparatively underrepresented (25%:75% female: male).
Through our Workforce Plan, we have taken active steps to strengthen gender representation at senior levels. As part of this work, seven women have recently been appointed as Leads across the organisation, broadening the leadership pipeline and increasing opportunities for women to progress into more senior decision-making roles.
We plan to continue addressing this through a sustained focus on leadership and management development, succession planning and strategic recruitment.
We have a good representation of disabled people with 30% self-identifying as disabled. As a comparison, in September 2025, the Scottish Government reported 14.2% of staff were disabled.
We have some representation of people from ethnic minority groups at 3.75%, an increase from our previous representation of 2.6%. In September 2025, for comparison, the Scottish Government reported a figure of 4.0%.
The information we have on sexual orientation and gender reassignment is that 1.25% of staff identify as LGBTQI+. In September 2025, the Scottish Government reported a figure of 8.1%.
Data on the current ILF Scotland workforce is robust in relation to age and sex. However, information on other protected characteristics – including ethnicity, disability, religion or belief, sexual orientation and gender reassignment – remains limited. This is largely due to non-completion of questions within staff surveys or individuals choosing the prefer not to answer option.
We continue to raise awareness across the organisation about the importance and benefits of sharing protected characteristic data, emphasising that all information is held in strict confidence and used solely to support equality monitoring and improvement.
As a positive action measure in recruitment, we actively encourage applications from individuals with protected characteristics to help broaden representation across our workforce. Like many public bodies, we recognise the ongoing challenge of achieving a workforce that fully reflects the diversity of the communities we serve, and this will remain a key area of focus in the years ahead.
The findings from our 2025 employee engagement surveys indicate (84% response rate):
100% of our staff can and do continue to work flexibly and remotely
Life / Balance Opportunities – 98.51% stated that they were in control of this most of the time
ILF Scotland continues to be an outstanding place to work
Our Accreditations
Equality Outcomes 2026 to 2028
These are the new Outcomes for 2026 to 2028. We have consulted with ILF Scotland staff and Advisory and Young Ambassadors Group members. Our Equality Committee and our SLT have recommended them to the Board, who have approved them. We will integrate these as SMART objectives in our business plan.
Outcome 1: Making inclusivity central to how we work and lead, strengthening our commitment to having a workplace where everyone belongs
Action: Over the next two years, we will embed inclusivity as a visible, measurable and shared responsibility across our organisation. We will continue to equip our staff with the skills to foster belonging, ensuring transparent policies and processes, as well our ongoing commitment to actively listen, engage and respond to diverse perspectives. Clear goals and accountability will track our progress and celebrate milestones in doing so, making inclusivity a core part of how we lead, collaborate and continue succeed together.
Outcome 2: Ensure our Equality Impact Assessment is inclusive of all of our relevant public body duties
Action: By the end of 2025 to 2026, review and update our Equality Impact Assessment Screening Toolkit and EQIA template to incorporate all other relevant impact assessments introduced by other legislation where we have a public body duty including the UNCRC, the Consumer Duty and the impending Human Rights Bill.
Outcome 3: Provide improved data on protected characteristics to improve the inclusivity of our services and to demonstrate alignment with Scottish Government equality priorities
Action: Develop our application forms, our online portals, our review process paperwork and processes and our digital systems to systematically request information relating to protected characteristics for applicants to and Recipients of both the Independent Living Fund and the Transition Fund. Monitor and analyse this data and report appropriately in line with good practice on data relating to protected characteristics to our SLT, Board, Equality Committee, Scottish Government and publicly as required.
Outcome 4: Increase our partnership working to improve equality outcomes for people living in Scotland and Northern Ireland
Action: Contribute to working parties, briefing papers, meetings, conferences, information sharing, etc. with the aim of driving improvements generally in equality and diversity. Attend meetings with relevant partner organisations to carry out benchmarking with other public bodies to improve the equality outcomes across the organisation as we continue on our Mainstreaming journey.
These equality outcomes will guide our progress and direction, which will be monitored by our Equality Committee. We will develop action plans and monitor and review these annually to ensure we remain on track and will publish and update our progress annually as well as updating plans with any relevant information due to unplanned and / or unforeseen national and international events.
Conclusion
We continue to set equality outcomes with the intention that we truly embed equality, diversity and inclusion into our strategic and annual delivery plans and our daily activities. We are pleased to report that we have achieved the majority of what we set out to do in the period of this plan. Some actions are ongoing and we have incorporated them in our actions for 2026 to 2028, as we continue to identify opportunities for improvement and as part of our ongoing commitment to our equality mainstreaming journey.
We agreed the actions we need to take to achieve our equality outcomes through engagement with and listening to the views of our Advisory Groups and staff. We discuss these with our Equalities Committee and with our Senior Leadership Team (SLT) and our Board formally approves them. Board members provide the necessary scrutiny to ensure that we meet our duties and that we consider potential equality impacts as part of our corporate decision-making.
Our SLT is responsible for promoting and embedding equality in our plans, projects and operational processes.
Each employee also has an individual responsibility for considering equality issues in all areas of the work we do and in working with others to continually enhance our processes and our contact with our applicants, Recipients and others.
We will continue to identify and implement innovative ways to understand the needs of our Recipients, listening and working hard, to learn and improve what we do.
We will use the employee equality metrics in this report, together with developing best practice, to support and inform our recruitment and employment practices, to improve our workforce equality and diversity and to promote the organisation as an employer of choice.
As a Non-Departmental Public Body, we ultimately aspire to continue to work in partnership with the Scottish Government and other Public Bodies, to be an inclusive employer and to continue to enhance the access to our services and the support provided to disabled people in Scotland and Northern Ireland.
Appendix I: Equal Pay Gap Information
We report our pay gaps using a single measure, comparing the average full-time equivalent earnings of men and women at March 2026. This includes both the mean and median hourly pay, excluding overtime. It is important to recognise that a gender pay gap reflects the difference in average earnings between men and women across the organisation as a whole and does not indicate unequal pay for comparable roles or work of equal value.
Gender Pay Gap by Grade
Administration
Grade A3 Female pay as a percentage of male pay: 105.74% Median Pay Gap: -5.76% Mean Pay Gap: -5.76%
Grade A4 No staff at A4
Specialist Professional and Technical
Grade B1 Female pay as a percentage of male pay: 103.61% Median Pay Gap: -3.61% Mean Pay Gap: -8.46%
Grade B2 Female pay as a percentage of male pay: 98.09% Median Pay Gap: -0.82% Mean Pay Gap: 0%
Grade B3 Female pay as a percentage of male pay: 111.65% Median Pay Gap: -11.62% Mean Pay Gap: -11.28%
Senior Leaders
Grade C1 Female pay as a percentage of male pay: 94.27% Median Pay Gap: 5.75% Mean Pay Gap: 0%
Grade C2 Female pay as a percentage of male pay: 93.32% Median Pay Gap: 6.67% Mean Pay Gap: 6.670%
Grade C3 Female pay as a percentage of male pay: not applicable Median Pay Gap: 0% Mean Pay Gap: 0%
CEO Grade SCS 1 Female pay as a percentage of male pay: not applicable Median Pay Gap: 0% Mean Pay Gap: 0%
All comparable jobs or work of equal value are paid on the same scale. The pay gap in 2025 to 2026 is entirely due to spinal placement on the grade and will even out as employees reach the top of their scale.
This is set out in table form below.
Gender Pay Gap by Grade
Job Type
Grade
Female pay as a percentage of male pay
Median Pay Gap
Mean Pay Gap
Administration
A3
105.73%
-5.76%
-5.76%
Administration
A4
n/a
n/a
n/a
Specialist Professional and Technical
B1
103.61%
-3.61%
-8.46%
Specialist Professional and Technical
B2
100.82%
0.82%
0%
Specialist Professional and Technical
B3
-111.65%
-11.62%
-11.28%
Senior Leaders
C1
94.32%
5.75%
0%
Senior Leaders
C2
93.32%
6.67%
6.67%
Senior Leaders
C3
n/a
0%
0%
CEO
SCS 1
n/a
0%
0%
Where men and women are undertaking work of equal value, they are paid a similar hourly rate and consequently the gender pay gap is low.
Appendix II: Equal Pay Statement
Equal Pay Statement
ILF Scotland is committed to the principle of equal opportunities in employment and to ensuring that all staff are treated fairly, consistently and without discrimination.
We believe that employees should receive equal pay for the same or broadly similar work, for work rated as equivalent, and for work of equal value, regardless of:
age
disability
ethnicity or race
gender reassignment
marital or civil partnership status
pregnancy or maternity
political beliefs
religion or belief
sex
sexual orientation
To achieve this, we operate pay and progression systems that are transparent, objective and free from unlawful bias. Our approach is underpinned by job evaluation, clear pay structures and regular monitoring to ensure equity is maintained and any emerging issues are addressed promptly.
Where a gender pay gap exists, this is primarily due to employees being placed at different spinal points within the grade, based on their time in post. Our pay structure is designed to ensure that staff progress through spinal points in a consistent and transparent way. As colleagues move through the scale, we anticipate that any current differences in average pay will narrow and even out over time.
As part of our commitment to fairness, dignity and equality at work, we are proud to be a Living Wage Employer. We ensure that all directly employed staff, as well as regular third-party contractors, are paid at least the real Living Wage as defined annually by the Living Wage Foundation.
This commitment reflects our belief that fair pay is a core component of promoting equality and reducing socio-economic disadvantage.
We will continue to monitor our pay practices and contractor arrangements to ensure ongoing compliance with Living Wage standards and alignment with our equality objectives.
ILF Scotland will continue to review its policies, practices and pay data to ensure that equal pay is embedded in all aspects of employment and that our workforce is supported to thrive in an inclusive and fair working environment.
Equality Duty Action Plan - 2025
1. Introduction
The Independent Living Fund Scotland (ILF Scotland) believes that no-one should be denied opportunities because of their race or ethnicity, a disability, their gender, or sexual orientation, their marital or civil partnership status, their age or religion, or due to any of the protected characteristics detailed in the Equality Act.
ILF Scotland will treat recipients, applicants and ILF Scotland staff equally and fairly. For staff, this commitment also extends to maternity status, working pattern, employment status, caring responsibility, and trade union membership.
ILF Scotland must comply with the Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012 and the specific duties designed to help Scottish public authorities meet the general duty. Regulation 4 of the specific equality duties requires that we base our Equality Outcomes on evidence, and involvement of equality groups.
The Public Sector Equality Duty regulates performance against equalities duties. From April 2020, ILF Scotland is required to report on the areas outlined below, every two years, apart from the Statement on Equal Pay, which is every four years. We also have a duty to publish diversity information about our board members. This report meets our general and specific duties under the Equality Act 2010 and outlines:
Mainstreaming the Equality Duty in ILF Scotland
Report on Progress
Board Diversity Duty
Employee Information
Gender Pay Gap Information
Statement on Equal Pay (covering sex only)
1.1 Background
The public sector equality duty came into force on 5 April 2011. The purpose of the duty is to ensure that public authorities consider how they positively contribute to a more equal society. It requires authorities to consider equality in all their functions, including decision-making, design, and delivery of services.
From 1 October 2012, the scope of the Act was extended to ban age discrimination, though this does not presently cover people under the age of 18.
The aim of the Equality Duty Action Plan is to demonstrate ILF Scotland’s commitment to the Scottish Government’s equalities agenda, mitigate the risk that equalities activities are not prioritised and align the activities with budgets and resources to cover short and medium-term objectives.
1.2 The General Equality Duty
Under the Equality Act 2010, public authorities are required to have due regard to the need to:
Eliminate unlawful discrimination, harassment and victimisation and other prohibited conduct.
Advance equality of opportunity between people who share a relevant protected characteristic and those who do not.
Foster good relations between people who share a protected characteristic and those who do not.
This duty is often referred to as “the three needs.” To comply with the duty, a public authority must have due regard to all three of these needs.
The Act explains that to meet the second need (advancing equality of opportunity), a public authority must consider the need to:
Remove or minimise disadvantage suffered by people with certain protected characteristics, where these are different from the needs of other people.
Encourage people with certain protected characteristics to participate in public life or in other activities where their participation is disproportionately low.
The Act also sets out that:
Meeting different needs includes (among other things) taking steps to take account of disabled people’s disabilities.
Fostering good relations means tackling prejudice and promoting understanding between people from different groups.
Meeting the general equality duty may involve treating some people more favourably than others.
Who should be aware of the General Duty in ILF Scotland?
1.3 Board Members
Set strategic direction, review performance, and ensure good governance of the organisation. The Depute Director, Scottish Government, Health and Social Care, appraises the Chair of the Board against a Diversity Objective.
1.4 Senior Managers
Oversee the design, delivery, quality, and effectiveness of the organisation’s functions.
1.5 Equality and Diversity Staff
Specific role in raising awareness and building capacity about the general duty. The Equality Lead in ILF Scotland is the Chief Executive Officer.
1.6 Communications Staff
Help ensure relevant equality information is available and accessible.
1.7 Frontline Staff
Need to be aware of how they can help to meet the needs of people with special characteristics.
1.8 Procurement
Need to be aware of how to build equality considerations into the organisation’s supply chain. In ILF Scotland, anyone tendering a contract should be aware of the Equalities Obligation and what we expect of organisations that we contract with.
1.9 Line Managers
Need to consider and be aware of how they apply Equality Duty on a day-to-day basis with reference to organisational employment policy and practice.
2. Key ILF Scotland Documents
The primary function of ILF Scotland is to operate a discretionary fund providing financial awards to over 4,000 disabled people in Scotland and Northern Ireland to help them live independently. ILF Scotland adheres to a suite of key policy documents to support our recipients, applicants, and staff. The policy suite is updated on an ongoing basis to support the Scottish Government’s strategic priorities.
ILF Scotland recognises the need to consider whether and how the outcome and delivery of any proposed new or amended policy might impact on people, specifically, what relevance the policy might have to people with protected characteristics.
The policy development lead will carry out a screening exercise to help determine if any proposed or amended policy / practice will directly or indirectly affect people. They should then complete either an Equality Impact Assessment (EQIA) or the No EQIA required declaration.
The policy lead must carry out the EQIA early, and as an embedded part of the policy development process, so that the assessment can shape, inform, and influence the policy proposals, and they should continue to revisit this assessment throughout the lifecycle of the policy.
2.2 ILF Scotland Strategy 2025 to 2028
The vision set out in the Strategic Plan identifies the integral part played by ILF Scotland in supporting independent living for disabled people across Scotland and Northern Ireland, and how ILF Scotland can support individuals through its funding role.
2.3 2025 to 2026 Business Plan
ILF Scotland will improve its evidence base by gathering information from recipients, applicants, and staff through the various use of equality monitoring forms, and where applicable, will use surveys, to strengthen its understanding of the needs and requirements of the disabled people the organisation supports.
This improved data will be reflected in enhanced information displayed in the Annual Corporate Report and online. Stronger management information will enable ILF Scotland to consider how it can better meet the general equality duty, its specific duty under the Act, and improve its service delivery.
3. What We Do To Promote Equality
Customer Facing Actions (CFA)
CFA Ref: CFA01
Action: Engage opportunities to encourage diversity of our Board membership and create dialogue with under-represented groups (specifically disabled people).
General Equality Duty: Advance Equality of Opportunity
Owner: Chair of the Board
Review: Ongoing through specific engagement opportunities
CFA Ref: CFA02
Action: Ensure that all our staff follow SSSC’s and NISCCs Codes of Practice. The Code is part of our Induction Pack for all staff. Refresher and updates are delivered as required.
General Equality Duty: Eliminate Discrimination Advance Equality of Opportunity Foster Good Relations
Action: Continue to amend our website to create clear visual communication, making appropriate use of audio / video and social media platforms, to increase accessibility and reduce barriers for disabled people. Follow good practice guidance on design for our website and all publications and provide documents in alternative languages and formats on request.
General Equality Duty: Eliminate Discrimination Foster Good Relations
Owner: Director of Policy
Review: New improved website with greater emphasis on accessibility, live June 2022. Achieved new UK Government Standards on Accessibility. Diversified and extended use of social media platforms. Improvements made to Fund literature in the Transition Fund application process. Accessibility internal working group established to review key material. Focus on making all key public documents accessible.
CFA Ref: CFA04
Action: EQIA exercise to be carried out and EQIA published for all new and revised external policies, the framework of this is determined by Scottish Government Ministers. EQIAs to be completed for other key business decisions
General Equality Duty: To comply with Equality Legislation and good practice Eliminate Discrimination Foster Good Relations
Owner: Director of Policy All Heads of Departments
Review: Completed and ongoing. Completed - EQIA Training for Management Team – May 2025. Ongoing refresher training will take place regularly.
CFA Ref: CFA05
Action: Improvements to application forms and guidance, all designed to be clear and accessible. Including access to Gaelic Language forms.
General Equality Duty: Advance Equality of Opportunity Foster Good Relations
Owner: Director of Policy
Review: In progress and ongoing – Gaelic Language forms not yet developed.
CFA Ref: CFA06
Action: All roadshows and events undertaken in accessible venues, with as wide a geographic spread as possible, bi-lingual advertising in Gaelic-speaking communities.
General Equality Duty: Advance Equality of Opportunity Foster Good Relations
Owner: Director of Policy
Review: Ensured all engagement events for the Independent Living Fund re-opening were held in accessible venues and that all related communication was produced in Plain Language and Easy Read. No events were held in Gaelic Language speaking localities.
CFA Ref: CFA07
Action: Equality check carried out on Board papers and all publications / key documents to ensure written communication is gender neutral.
General Equality Duty: Eliminate Discrimination
Owner: All Heads of Department
Review: Ongoing
CFA Ref: CFA08
Action: Equality clauses added to all contracts as part of tendering / procurement process and submissions measured against equality criteria.
General Equality Duty: Advance Equality of Opportunity Eliminate Discrimination
Owner: Head of Finance
Review: Ongoing
CFA Ref: CFA09
Action: Denholm House is an accessible building with an induction loop. ILF Scotland promotes such provision through its service level agreement with the Scottish Government.
General Equality Duty: Foster Good Relations
Owner: Chief Operating Officer
CFA Ref: CFA10
Action: Through our Corporate Parenting Plan, we will further develop our communications strategy to target care experienced young people and those that support them to ensure they are aware of ILF Scotland Transition and Re-opened Funds. We will ensure ILF Scotland staff and Board Members are aware of the principles of Corporate Parenting through training courses and induction programmes.
General Equality Duty:
Advance Equality of Opportunity
Owner: Director of Policy
Review: Communications Strategy updated. Completed - Training delivery September / October 2024
CFA Ref: CFA11
Action: Facilitate meetings of the Co-Production Working Group every two months in 2024 to 2025, with the first meeting to be scheduled for June 2024. Report on learning from the first two months of receiving applications to the re-opened fund and work together with the group and others as required to further develop policies around the key issues raised by disabled people and others at the re-opening engagement events. Arrange further co-production opportunities with our recipients and others as part of our strategic planning consultations in the latter part of 2024 to 2025.
General Equality Duty: Advance Equality of Opportunity Foster Good Relations
Owner: CEO Director of Policy SLT
Review: Ongoing
Staff Actions (SA)
SA Ref: SA01
Action: Offer employment opportunities for volunteer / student placements for young people with a disability that places them at a significant disadvantage in the job market. Offer social work student placements to promote the Social Model of Disability within statutory social work.
General Equality Duty: Advance equality of opportunity
Owner: CEO Director of Independent Living
Review: Student placements opportunities offered annually – September 2025
SA Ref: SA02
Action: Continue induction training for Board Directors and staff on Diversity and Equality.
General Equality Duty: Eliminate discrimination
Owner: Director of Business Services
Review: Ongoing - DET Training for all staff and Board Directors during induction.
SA Ref: SA03
Action: Gaelic Language Plan, with responsibility held at Senior Management level, helping to raise awareness and culture of relevance to ILF Scotland’s staff and recipients.
General Equality Duty: Advance equality of opportunity Foster good relations
Owner: Director of Policy
Review: Awareness training delivered across the organisation – Feb 2022. On hold since then due to other completing priorities and no requirement currently for legislative compliance. Will pick up in next Strategic Plan.
SA Ref: SA04
Action: Information on Equality and Diversity is included in the Staff Handbook / HR Policies and forms part of the Induction for new staff.
General Equality Duty: Advance equality of opportunity Eliminate discrimination Foster good relations
Owner: Director of Business Services
Review: Complete and ongoing for new staff. Refresher sessions for current staff. New Equality and Diversity Policy published June 2025.
SA Ref: SA05
Action: ILF Scotland continues to promote best practice in making sure the office space is suitable for people with differing needs, for instance with an induction loop and disabled access to the building.
General Equality Duty: Foster good relations Eliminate discrimination
Owner: Finance and Business Services
Review: MOTO and Shared Service Agreement with the Scottish Government.
SA Ref: SA06
Action: Adhere to ILF Scotland HR policies on equality and diversity in the workplace, including work-life balance, development, promotion, work opportunities and recruitment.
General Equality Duty: Advance equality of opportunity
Owner: Director of Business Services
Review: Completed for all staff and on-going refreshers.
SA Ref: SA07
Action: Regular Conversations take place between staff and line managers and include specific reference to wellbeing to allow any concerns to be acted on.
General Equality Duty: Foster good relations Eliminate discrimination
Owner: Director of Business Services
Review: Ongoing regularly through 1-2-1s and training.
SA Ref: SA08
Action: Continue to increase awareness of mental health issues as an equality issue.
General Equality Duty: Advance equality of opportunity Eliminate discrimination Foster good relations
Owner: Director of Business Services
Review: 7 x Mental Health First Aiders. Mental Health and Personal Resilience training offered regularly to all staff and Board Directors.
SA Ref: SA09
Action: Continue to increase equality for disabled people living in poverty
General Equality Duty: Socio-economic duty
Owner: Director of Independent Living
Review: Provide regular welfare rights and income maximisation training to all operational staff. Provide an in-house welfare rights service for staff to respond to ILF recipients.
SA Ref: SA10
Action: ILF Scotland adheres to the SG (Scottish Government) Fairness at Work policy, which covers equality and diversity.
General Equality Duty: Foster good relations Eliminate discrimination
Owner: Director of Business Services
Review: Work with recognised union - PCS to ensure ILF Scotland works to the Fairness at Work principles.
SA Ref: SA11
Action: Raise awareness of neurodiversity and provide staff training to cover this area specifically as part of our equality and diversity training. Provide more detailed training to front line staff working in both Funds so that they can provide better informed customer service to those applications and recipients who are neurodivergent.
General Equality Duty: Advance equality of opportunity
Owner: Director of Business Services
Review: Raise awareness workshops between 2024 to 2026 (underway)
4. ILF Scotland HR Policies on Equality and Diversity
ILF Scotland has designed its induction procedures to ensure diversity issues are included and staff are aware of a range of advice, guidance and support provided by ILF Scotland HR team.
4.1 Equal Opportunities Policy Statement
ILF Scotland will treat all staff equally irrespective of their sex, marital / civil partnership status, maternity status, age, race, ethnic origin, sexual orientation, disability, religion, or belief, working pattern, employment status, gender identity, caring responsibility, or trade union membership.
4.2 Diversity Policy Statement
ILF Scotland is committed to increasing the diversity of staff within the organisation. We will develop all our staff, ignoring all irrelevant differences, in their management and development. Furthermore, we will positively value the different perspectives and skills of all staff and make full use of these in our work.
4.3 Resources Available on Diversity and Equality
Diversity Training
Flexi policy and working patterns (flexible working)
Equality staff networks
Inclusive communication
How staff can access the Employee Assistance Programme to support wellbeing
5. Forward Planning
Active consideration of equality will help ILF Scotland to identify ways in which to improve evidence gathering and engagement, to help improve the quality of services it provides, making them more responsive to customer and staff needs, leading to better outcomes.
Senior Managers and Board Directors have a vital role to play in giving a clear and consistent message about the importance of promoting equality and diversity. Through visible leadership, the Senior Leadership Team will ensure that it reflects equality in performance reporting and that staff are clear ILF Scotland adopts a zero-tolerance approach to discriminatory behaviour and builds the capacity of all staff to consider and promote the equality duties.
5.1 Annex A: Protected Characteristics
Protected Characteristics
Age Disability Gender reassignment Marriage and civil partnership Pregnancy and maternity Race Religion and belief Sex Sexual orientation Socio-economic background
The socio-economic duty is contained in Section 1 of the Equality Act 2010 although it has never been enacted. The duty would require public authorities to actively consider the way in which their decisions increase or decrease the inequalities that result from socio-economic disadvantage. ILF Scotland is committed to supporting disabled people living in poverty.
6. Equality and Diversity Plan – Action Plan (AP)
AP Ref: AP01
Action: Staff satisfaction survey – use to provide data on bullying and harassment, wellbeing, and opportunities. Compare data in-year. Consider adding question to survey to seek staff ideas on improving diversity.
General Equality Duty: Advance equality of opportunity Eliminate discrimination Foster good relations
Owner: Director of Business Services
Update: Working group formed annually to consider survey and improve offering
Review: 2024 to 2025 Staff Survey completed.
AP Ref: AP02
Action: The TF online application process reduces access barriers to recipients as they do not need to phone or write to us to access information and do not need to complete a written application form.
General Equality Duty: Foster good relations
Owner: Director of Policy
Update: Online application process improvements implemented 2020 to 2021.
Review: Keep opportunities for further improvements under review. Ongoing.
AP Ref: AP03
Action: Equality and Diversity given high profile in induction training for Board Directors
General Equality Duty: Advance equality of opportunity Foster good relations
Owner: Director of Business Services
Update: New Board Directors 2023 onwards
Review: New Board Directors attend Disability Equality Training. Board Directors attend Neurodiversity workshop sessions 2024 to 2026.
AP Ref: AP04
Action: Increase awareness of cultural importance of Gaelic and promote learning by providing training and BnG presentation to Board.
General Equality Duty: Foster good relations
Owner: Director of Policy / Director of Business Services
Update: Progress started on a voluntary basis at present well in advance of requirement to produce Plan in full.
Review: On hold
AP Ref: AP05
Action: Ensure all venues for roadshows are accessible and bi-lingual advertising in Gaelic-speaking areas.
General Equality Duty: Eliminate discrimination Foster good relations
Owner: Director of Policy
Update: No public events held in Gaelic-speaking areas.
AP Ref: AP06
Action: Actions to promote increased awareness of Mental Health in the Workplace
General Equality Duty: Advance equality of opportunity Eliminate discrimination Foster good relations
Owner: Director of Business Services
Update: Training: Supporting each other in a Crisis - April 2020 Personal Resilience - March 2021 Returning to Workplace - May 2022 7 x Mental Health First Aiders trained and in post.
Review: Continue Mental Health and Resilience workshops and raising awareness annually (completed October 2025).
Data Sharing Agreement Terms and Conditions
between Independent Living Fund (ILF) ScotlandandScottish Local Authorities
1. Document Control
Current Version number
00.7
Title
Data Sharing Agreement for Independent Living
Summary
An official Agreement between the Independent Living Fund Scotland and Scottish Local Authorities. This Agreement takes account of the regular and routine sharing of personal data relating to Applicants for / Recipients of ILF Scotland funding between the parties to this Agreement.
Date
<<Insert Date>>
Author
Privacy and Improvement Manager
Owner
Director of Digital and Information Services
Version Control
Date
Version
Summary of Changes
Author
09/12/2021
v00.1
Working Draft
Marianne Craig
15/02/2024
v00.2
Comments & corrections
Laura Earley
23/01/2023
v00.4
Formatting changes
Laura Earley
14/02/2023
v00.5
Comments & corrections
CLO
15/02/2023
v00.6
Formatting changes & corrections
Laura Earley
26/03/2024
v00.7
Working Draft & changes to data sharing approach
Laura Earley / Paul Hayllor
2. Interpretation of Terms Used in This Agreement
Term or expression
Definition
Agreed Purpose
has the meaning given to it in paragraph 5
Agreement
means this data sharing Agreement
Applicant
means an individual applying to receive an ILF Scotland Award
Award Manager
means an individual made responsible by the Recipient for managing an ILF Scotland award, whether by choice or by virtue of reduced capacity in relation to an impairment
Controller
shall have the meaning given in the UK GDPR
Data Loss Event
means any event that results, or may result in unauthorised access to Personal Data held under or in connection with this Agreement, and / or actual or potential loss and / or destruction and / or corruption of Personal Data in breach of this Agreement, including but not limited to any Personal Data Breach
Data Protection Legislation
means (i) the UK GDPR and any applicable national implementing laws as amended from time to time; (ii) the Data Protection Act 2018 to the extent that it relates to the Processing of Personal Data and privacy; and (iii) any other law in force from time to time with regards to the processing of Personal Data and privacy, which may apply to either party in respect of its activities under the Agreement
Data Subject
shall have the meaning given in the UK GDPR
Data Subject Request
means a request made by, or on behalf of, a Data Subject in accordance with access and other rights granted to the Data Subject pursuant to the Data Protection legislation in respect of their Personal Data
GDPR
means the UK General Data Protection Regulation
ILF Scotland Award
means funding from ILF Scotland awarded to a Recipient
Information Commissioner’s Office
means the United Kingdom’s Supervisory Authority
Personal Data
shall have the meaning given in the UK GDPR Processed by either party in connection with this Agreement
Personal Data Breach
shall have the meaning given in the UK GDPR
Process
shall have the meaning given in the UK GDPR and Processing shall be construed accordingly
PSN
means a Public Service Network which is an assured network used by the public sector to securely share data
Recipient
means an individual receiving an ILF Scotland Award
Scottish Local Authority
means a public body incorporated under the Local Government etc. (Scotland) Act 1994
3. Parties to the Agreement, Roles, Scope and Purpose of the Agreement
This Agreement has been prepared to support the regular and routine sharing of data between:
Legal name of parties to the Agreement & Head Office address
Role for the purposes of the Data Protection Legislation e.g. Controller / Processor
Independent Living Fund Scotland Limited, a company limited by guarantee registered in Scotland (Company Number SC500075) and having its registered office at St Andrews House, Edinburgh, EH1 3DG
Controller
[Insert Local Authority], a local authority incorporated under the Local Government etc. (Scotland) Act 1994 and having its head office at [insert office address]
Controller
The above are hereafter referred to as the parties.
3.1. Role of the Parties as Controllers
The parties acknowledge that for the purposes of the Data Protection Legislation, each party is a Controller in its own right in respect of the processing of Personal Data on its own behalf and in particular:
ILF Scotland shall be a Controller where it is processing Personal Data in relation to ensuring the effective management and administration of ILF Scotland funding generally.
The Local Authority shall be a Controller where it is processing Personal Data in relation to supporting an Application for / Recipient of ILF Scotland funding.
Each party shall comply with all applicable laws and regulations (as amended from time to time) in relation to the performance of this Agreement, in particular each party shall:
in relation to the processing of Personal Data, comply with its obligations as a Controller under the current Data Protection Legislation; and
comply with other sector specific legislation including the Equality Act 2010 and the Protection of Vulnerable Groups (Scotland) Act 2007.
3.2 Scope of the Agreement
This Agreement takes account of the sharing of legitimate and proportionate information relating to the social care provision for new Applicants and / or Recipients of ILF Scotland funding. The information will be shared between ILF Scotland staff within the Self-Directed Support Teams and Social Work or Occupational Health professionals within the Scottish Local Authority.
3.3 Purpose of the Agreement
This Agreement will commence on [INSERT DATE] and shall continue in force until terminated in accordance with paragraph 15 below.
The aim of this Agreement is to:
facilitate the sharing between the parties of financial information and Personal Data relating to each Applicant / Recipient, to enable the administration and management of the ILF Scotland Award(s) for which the Local Authority provides support to an Applicant / Recipient or an Award Manager managing an award on behalf of a Recipient; and put in place a framework which will allow this Personal Data to be exchanged in ways which respect the rights and freedoms of individuals and in compliance with the law.
4. Description of the Data to be Shared
The following table sets out the personal data categories which can be shared between the parties:
Data Category
Controller(s)
the Applicant / Recipient’s full namefinancial details of the Applicant / Recipient’s ILF Scotland Awardthe Applicant or Recipient’s contributionsthe case reference numberpostal addressNational Insurance Numberdate of birthname and contact information for Managers of award funding where a Recipient does not manage their own fundingdetails of conversations held between Award Managers, Recipients and ILF Scotland Assessorsdetails of health and physical disabilities, including medical diagnoses (from a third-party healthcare professional) which may require changes in funding provision
ILF Scotland
the Applicant / Recipient’s full namedetails of any funding made to the Applicant / Recipient by the Local Authoritydetails relating to the Applicant / Recipient’s support needs, assessment and support plandetails of conversations held between Award Managers, Recipients and Social Work Professionalsdetails of health and physical disabilities, including medical diagnoses (from a third-party healthcare professional) which may require changes in funding provision
Local Authority
5. Description of the Purpose(s) of the Sharing
The parties consider the sharing of this data to be necessary to meet the aims outlined in section 2.1 above. The sharing will benefit the individuals applying for / in receipt of an ILF Scotland Award by aiding the effective management of such ILF Scotland Award and will benefit society by aiding the proper administration of public funds.
Personal Data is shared by the parties pursuant to this Agreement for the following purposes, to allow the parties:
to establish the identity of data subjects within a Local Authority who are applying for / in receipt of ILF Scotland funding
to ensure the correct identity of the Applicant / Recipient
to offer increased safeguarding for the Applicant / Recipient
to ensure the additionality of ILF Scotland funding
to ensure the Applicant / Recipient is utilising the funds received effectively
to ensure ILF Scotland Awards are maintained and managed appropriately and efficiently
to identify whether the Applicant / Recipient is receiving agreed hours of support
to identify financial hardship;
to ensure effective communication and implementation of any changes to the ILF Scotland Awards
(all points listed above are taken to be the Agreed Purpose).
Personal Data shall only be shared for the Agreed Purpose, and the parties shall not process Personal Data in a way that is incompatible with the Agreed Purpose.
6. Data Accuracy Assurance
The parties have a responsibility to check the quality and accuracy of the financial information and Personal Data which they hold, with particular emphasis on checking the accuracy and quality of data to be shared.
Each party undertakes to notify the other as soon as practicable if an error is discovered in, or changes are made to, the financial information or Personal Data which has been provided to the other party to ensure that the parties are then able to correct or update their respective records.
7. Lawful Bases for Processing
Without detriment to any other lawful basis that may be applicable, the following are the core legal bases for each of the parties to process Personal Data shared in line with this Agreement:
Party
GDPR Article 6 Condition(s) Personal Data
GDPR Article 9 Condition(s)Special Categories of Personal Data
ILF Scotland
6(1)(b) – Processing is necessary for the performance of a contract to which the Data Subject (the Applicant / Recipient) is party, or in order to take steps at the request of the Data Subject prior to entering into a contract.
9(2)(h) – Processing is necessary for the purposes of the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State law.
Local Authority
6(1)(e) – the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
8. Data Security and Loss Management
8.1 Security
Each party shall ensure that it has in place throughout the term of this Agreement appropriate technical and organisational measures to protect against a Data Loss Event, having taken account of (i) the nature of the Personal Data (and that personal data potentially includes Special Category Data) to be protected, (ii) the harm that might result from a Data Loss Event; (iii) the state of technological development; and (iv) the cost of implementing any measures to mitigate against the occurrence of a Data Loss Event.
The primary means of data transfer will be by the secure LA portal which is managed by ILF Scotland. Each Local Authority Social Worker making an application on behalf of a data subject will have a secure login to the system supported by multifactor authentication prior to allowing them to access the applications portal. This is the same portal that is used currently to confirm the details of the Care Schedule and meets the security requirements of both Scottish Government and the Local Authority Digital Office. This is now in full use across all local authorities in Scotland and should be considered as the primary secure data sharing platform.
Both parties shall ensure that there is either (i) a fully secured and encrypted email system in place for the exchange of Personal Data or Special Category Data as foreseen by this Agreement, or (ii) an alternative secure method for the exchange of information agreed between the parties, which might include telephone If the Local Authority does not have appropriate encryption measures in place on its email servers, ILF Scotland will arrange for an alternative secure system such as Huddle to be used to enable secure and restricted access to data for designated individuals within Local Authority Offices.
8.2 Data Loss
Each party will ensure that the other party is notified of any Data Loss Event, or significant data security risks, affecting shared Personal Data within 24 hours of becoming aware of the same.
The parties will, where appropriate, work together to rectify any such Data Loss Event or mitigate any such risk to data security, including notification to the Information Commissioner’s Office and to affected individuals if required.
9. Transparency
Both parties will clearly inform Data Subjects about how their Personal Data will be processed in connection with the Agreed Purpose in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
10. Retention and Deletion
During the terms of this Agreement, within one (1) month following the date of the cessation of an ILF Scotland Award pursuant to or in connection with which the sharing of Personal Data by the parties was undertaken, each party shall:
securely delete or securely return all Personal Data provided to it by the other party pursuant to this Agreement (and any copies of it) in relation to that ILF Scotland Award; and
certify in writing to the other that, to the best of its knowledge and belief, all such Personal Data (and any copies of it) have been securely deleted or securely returned, unless the party is required by law to retain the data.
In either case, if a party is required by law to retain any Personal Data, that party shall advise the other in writing of such requirement.
11. Rights of the Data Subject
Where either party receives a Data Subject Request, it shall be responsible for actioning the same in accordance with the Data Protection Legislation.
The parties each agree to provide such assistance as is reasonably required to enable the other party to comply with Data Subject Requests relating to the Agreed Purpose within the time limits imposed by the Data Protection Legislation.
12. Freedom of Information
All parties are subject to the Freedom of Information (Scotland) Act 2002 and the Environmental Information (Scotland) Regulations 2004 and / or any other codes or regulations applicable from time to time relating to access to public authorities’ information (FOI).
All parties agree to provide reasonable cooperation, upon written request, to enable any party to comply with its obligations under or in relation to FOI or FOISA.
The final decision on disclosure of any information under FOI or FOISA will be made by the organisation to which the request was directly made.
13. International Transfers of Data
All parties agree that in the event that Personal Data pursuant to this Agreement is required to be transferred outside of the UK, all other parties shall be notified in writing and ensure that any such transfer complies with the Data Protection Legislation.
14. Data Sharing Approach
The primary data sharing approach will be via the secure applications portal and thereafter via email, letter and / or in-person / telephone conversations. All data collected in this way will then be imported and stored in secure database systems which will only be accessible to approved personnel on a need-to-know basis only. This secure database will subsequently be used to push email notifications to the approved local authority personnel to notify them of updates and confirmation requirements of new care packages and request them to log in to the portal to review and approve new updates. The intention behind this is to reduce and limit the sharing of personal data in transit with as much as possible being completed in the LA Portal. Any data shared via email must use fully encrypted public sector networks and be minimised as much as possible by both parties. ILF Scotland has access to separate secure file sharing tools and these can be used on specific cases by exception if required but would be discussed separately (Huddle is the secure system).
Agreement
15. Termination of Agreement
This Data Sharing Agreement will terminate upon the date of cessation of all Recipients of ILF Funding Awards, unless terminated earlier by either party by serving not less than three (3) months’ notice in writing to the other party.
This Agreement will be reviewed every five years or sooner if appropriate.
16. Governing Law
This Agreement shall be governed and construed in accordance with Scots law and both parties hereby irrevocably submit to the exclusive jurisdiction of the Scottish Courts.
Transition Fund Price Guide
ILF Scotland Transition Fund Price Guide
updated 29 September 2025
We frequently receive requests for funding for a range of items and services where the average cost falls within certain price ranges. We have used this information to create a Price Guide.
To make it easier to apply, if the cost of the item or service you would like funding for is within the price guide, or close to it, you do not need to provide us with a quote. This will help us process these requests more quickly.
The cost of items in our price guide should enable people to purchase good quality, normally mid-range items and services that allow the applicant to achieve their desired goals. This approach also enables us to assist as many young people as possible in a fair and consistent way.
It is, however, only a guide. We assess all requests on an individual basis, and you can apply for things in this guide at a higher cost if needed but you must include a quote and, in addition, explain why you need these items or services to meet your goals.
We do not wish to limit a young person’s ambition or creativity around the goals they want to achieve so you can apply for things that do not feature in this guide, but you must submit a quote with your application.
You may, in addition to the more general items in the price guide, have requirements for specific items related to your disability and we are more than happy to discuss these with you.
Item / Typical Funding Award
Mobile Phone Handset (sim free): Up to £600
Computer / Tablet - General Use: Up to £600
Computer / Tablet - Graphics or Gaming use: Up to £1,000
Computer / Tablet Accessories: Up to £200
Drawing Tablet: Up to £300
3D Printer: Up to £350
Headphones: Up to £80
Camera (DSLR or Video): Up to £500
Camera Accessories: Up to £200
Gym Membership (annual): Up to £500
Specialised clothing related to funded activity: Up to £250
Personal Trainer Sessions: Up to £40 per hour
Sports Equipment (small items, consumables): Up to £250
Sports Equipment (larger items, golf clubs etc): Up to £500
Golf Membership: Up to £250
Camping Equipment: Up to £250
Kayak / Canoe / Paddleboard: Up to £350
Musical Instruments: Up to £600
DJ Equipment: Up to £600
Recording Equipment / Software: Up to £400
Starter Toolkit for Apprenticeship: Up to £500
Personal Protective Equipment: Up to £250
Bicycle / Tricycle (pedal): Up to £600
Bicycle / Tricycle (electric assisted (e-Bike)): Up to £1,000
Bicycle / Tricycle (electric / adapted for disability): Up to £1,500
Books (related to a course of further education): Up to £300
Art / Craft Materials: Up to £250
Sewing Machine: Up to £250
Cricut Machine: Up to £300
Art / Music / Drama Lessons: Up to £45 per hour
Driving Lessons (Standard non rural, manual and automatic): Up to £50 per hour
Wheelchair Powerpack: Up to £1,000
Beauty Business Start-Up Kit: Up to £350
Social Return on Investment (SROI) Evaluation - Northern Ireland
Social Return on Investment (SROI) Evaluation - Northern Ireland
February 2024
Sponsored by the ILF Scotland Stakeholder Group in Northern Ireland and the Advisory Group in Scotland.
1.0 Introduction
448 people in Northern Ireland (NI) received a combined total of £6.85 million from the Independent Living Fund (ILF) in the financial year 2018/19. A Social Return on Investment (SROI) study in 2019 1 found that for each £1 distributed in NI by ILF in 2018/19, £10.89 was generated in social value. The stakeholders benefitting were, Recipients, Personal Assistants (PAs) Health & Social Care Trusts, Families and informal carers and the Independent Living Movement.
Impact for recipients was derived through five outcomes:
Emotional well being
Health maintenance
Sustaining natural support
Personal development
Living independently
2.0 Aim
An update of the study to measure the extent the SROI sustained in the subsequent four years was commissioned by the NI Stakeholder Group in the summer of 2023.
3.0 Method
Existing 2019 data was reviewed and determined to remain accurate for use in the current analysis.
Six personal story interviews were undertaken with one new and three previous (2019) contributors, and two new Award Managers who are also members of the NI Stakeholder Group.
The financial proxies used in the 2019 study were then reviewed based on relevance and accuracy in line with policy and inflationary changes in the subsequent four-year period
4.0 Findings
349 people in Northern Ireland received £6.85 million from the Independent Living Fund (ILF) in the financial year 2022-23. The consultations with recipients, carers, award managers, and the NI Stakeholder Group, evidence that outcomes accrued for stakeholders in the 2019 study have been sustained and in some cases have been enhanced in the subsequent period.
The combined influence of emotional wellbeing, health maintenance, sustaining natural support and ‘getting on with life’ continues to demonstrate a clear preventative effect as recipients are better positioned to manage and overcome challenges they encounter in daily life.
Recipients felt in control of their lives and could stay connected with family, friends, and their community. In cases where they were living with their parents, they used the fund to socialise, volunteer and pursue further education. This provided respite for parents and made the recipient feel independent and in no way a burden on their parents, family, and friends.
“Getting out and volunteering which the fund helps me with makes me feel less dependent on family and friends and this helps me maintain good relationships with my nearest and dearest”.
All appreciated the flexibility of ILF and gained confidence and belief from being able to manage the fund. Recipients referenced the health and wellbeing benefits from using the fund.
“It improves my quality of life, mental health, makes me happy and independent. My PA accompanies me to go swimming, go on forest walks, go shopping, get my make-up and nails done, help me to choose outfits and attend hospital appointments”.
One recipient in receipt of ILF since aged 18, reflected on how the fund had enabled him to live a fulfilling adult life. The fund facilitated a journey of learning to be independent and increased ambition about what could be achieved in life.
A recipient who recently completed a master’s degree in international business felt that this would not have been possible without ILF as they were able to use it to assist with exam preparation, course work and assignments both at home and on-campus. With the qualification secured, the recipient is now using the fund to assist with job searching and interview preparation and attendance.
“ILF enabled me to think about what is possible…I did a master’s degree which I couldn’t have done it without ILF, It set me up to succeed”
One recipient is active in lobbying and campaigning for disabled people rights and supports for independent living and is a highly respected influencer in this area. Being able to attend meetings and events means he can teach others about independent living, act as a role model and use his experience and expertise to influence policy on disability.
Despite the challenges presented by Covid 19, interview feedback from the recipients and award managers indicated that access to the fund was a critical enabler particularly for health maintenance and resilience throughout the pandemic. Those interviewed emphasised the competence, reliability, and loyalty of their PAs who worked effectively to ensure all public health guidelines were adhered to, referencing their contribution as "truly lifesaving".
Additional funding was available to meet costs associated with the pandemic to ensure PAs who had to self-isolate could receive their full salary while on leave, employment of additional staff while PAs were self-isolating, and for Personal Protective Equipment (PPE). Furthermore those interviewed referred to the empathy, understanding and flexibility experienced in their correspondence with ILF during this unprecedented period. One recipient was able to use the fund to mitigate boredom and remain mentally stimulated during lockdown.
“ILF were great during Covid, they allowed me to use it for creative arts projects and pay a curator to give me ideas, it kept me stimulated and improved my wellbeing”.
The inflexibility of statutory care packages and to some extent Direct Payments and how this compares with the impact of ILF was a recurring theme throughout the consultation.
“Trust care packages helped me to survive, Direct Payments let me live; the Independent Living Fund gives me a life a worth living”
4.1 SROI Results
ILF through its £6.85 million allocation to recipients in 2022/23 generated a social value of £1: £13. This is based on a Total Present Value of £89,109,708 created against the input of £6,850,000. The social value generated by ILF for stakeholders demonstrates extended impact and value for money. The calculations applied financial proxies to twenty-one outcomes (See Appendix 1) for five material stakeholder groups evidenced through the primary and secondary research. Value accrued per stakeholder is segmented in Table 1.
Table 1: Social Value by Stakeholder
Recipients: 80% HSCT's: 16% Personal Assistants: 2% Family / Carers: 1% Northern Ireland Civic Society: 1% Total: 100%
It is necessary to discount the values generated by each of the financial proxies used to reduce the risk of over claiming. While there is a likelihood that through Self Directed Support some of the health and well-being outcomes may have been achieved, it is evident from current statutory funding levels and policy priorities that equivalent levels of funding to the ILF allocation to support independent living in the community would not have been made available. We have therefore attributed low levels of deadweight 2 (5-10%) to the calculations.
There is no robust evidence base emerging that ILF has displaced domiciliary or homebased services rather the contrary. It has strengthened existing assistance requirements based on independent living principles. Reduced isolation, improved relationships, and increased capacity to contribute to their local community and civic society were among recipient outcomes reported in 2019 & 2023.
In the absence of ILIF there would not have been sufficient community or voluntary services or inputs from family to achieve equivalent outcomes for recipients. The SROI ratio is calculated over five years to reflect the longer-term impacts for stakeholders if the fund was no longer available. Given the complex needs of many recipients the drop off in impact would be in the range of 20-50% in years 2-5.
4.2 Sensitivity Analysis
As the SROI analysis contains estimations and assumptions, it is prudent to review where these decisions have had a significant effect on the overall SROI calculation and to consider, therefore, the assurance that can be placed on such figures. As an evaluative analysis, the study contains confirmed data regarding ILF funded outputs. The research makes extrapolated assumptions on the numbers impacted based on the data collated in 2019 and 2023 through the desk top review process and the mixed method consultations with participants, employers, and stakeholders.
The sensitivity analysis explores the impact on the SROI ratio of changing some of the study’s key assumptions. Discount rates thought to be significant were amended to clarify the impact of changing attribution, deadweight, or displacement. Outcome values were also adjusted. This sensitivity analysis did not significantly alter the final calculations which are considered assured.
5.0 Summary
The numbers in receipt of ILF in NI have decreased by 99 from 448 in 2019 to 349 in 2023 due to natural causes. Despite this, the social value accrued from ILF has increased from £1:10.89 to £1:13 which means that the fund’s overall impact for stakeholders has increased by 20%. Recipients were the main benefactors with their overall share of the social value accrued increasing from 77% in 2019 to 80% in 2023. This has been achieved against the backdrop of an ageing ILF cohort, increasing operational and inflationary pressures on public services, and the unprecedented Covid-19 pandemic.
Appendix 1
Financial Proxies and sources used for the SROI calculations:
Relief from depression/anxiety (£40,442) HACT Social Value Bank
Sustaining full time employment (£14,433) HACT Social Value Bank
Belonging to a social group (£1,850) HACT Social Value Bank
Increased frequency of interaction with friends, relatives & neighbours- £7,750
Value of lives saved (£1,553,653) Microsoft Word - pl2-eco (health-ni.gov.uk)
Feeling in control of life (£15,894) HACT Social Value Bank
1 Undertaken by the Centre for Independent Living Northern Ireland & Gauge Impact. 2 Deadweight is an estimation of the value that would have been created if ILF was not available to recipients.
Social Return on Investment (SROI) Evaluation - Scotland
Social Return on Investment (SROI) Evaluation - Scotland
February 2024
Sponsored by the ILF Scotland Stakeholder Group in Northern Ireland and the Advisory Group in Scotland.
1.0 Introduction
Social Return on Investment (SROI) studies on the Independent Living Fund (ILF) in Northern Ireland (NI) in 2019 1 and 2023 2 found that for each £1 spent £10.89 and £13 respectively was generated in social value. The stakeholders identified were Recipients, Personal Assistants (PAs) Health & Social Care Trusts, Families, informal carers, and NI civic society.
2.0 Aim & Rationale
In August 2023, the potential of replicating the SROI methodology adopted for the ILF NI studies to calculate the social value generated by ILF Scotland was discussed by the ILF Scotland Advisory Group. After a detailed presentation of the ILF NI methodology and an explanation of the caveats and assumptions 3 that would underpin an equivalent study for ILF Scotland, the Advisory Group agreed to proceed. This study therefore represents the final instalment of a trilogy of social impact reports on the ILF in Northern Ireland and Scotland.
3.0 Method
The extent to which the five outcomes below evidenced and valued for NI recipients in the 2019 and 2023 studies were relevant in Scotland was tested during nine semi-structured interviews with ILF Scotland recipients / award managers.
Emotional well being
Health maintenance
Sustaining natural support
Personal development
Living independently
Discussions were facilitated with ILF Scotland to determine the stakeholders for the study. The direct and indirect stakeholders for the ILF NI studies were used as the starting point for the discussions. From this, some differences in the Health & Social Care systems and the administration of ILF in both regions emerged.
The financial proxies used for the ILF NI SROI studies were then reviewed to determine how they could be applied to the ILF Scotland SROI calculations. 18 of the 21 outcomes for the NI studies (See Appendix 1) were sourced from UK wide proxy banks so were material to ILF Scotland. The remaining three outcome proxies were amended to reflect differences in the costs of nursing and residential care, hospital admissions and the minimum wage between Northern Ireland and Scotland.
4.0 Consultation
This section summarises the key findings from the consultations with the nine ILF Scotland recipients, two of whom were award managers. Five have been in receipt of ILF for over 20 years with the others benefitting from the fund for 14,16,17 and 19 years, respectively.
All referenced ILF being an enabler for independent living. This was a combination of getting out of the house to volunteer, socialise with friends, going to the cinema and attending family events. Being able to sustain regular exercise (swimming) and find new hobbies (model aircraft flying) was according to one recipient directly attributable to ILF. With the support of their PA, one recipient was able to use public transport to visit their ageing parents regularly who live relatively close by.
Two of those interviewed are on the boards of voluntary and community organisations and advocate and campaign for disabled people, asylum seekers, and those who are homeless. Both had long and successful careers and having ILF to assist with administration and attending meetings enables them to use their experience and expertise to support marginalised groups and influence national policy on disability and social inclusion.
The health maintenance aspect of ILF was evident throughout. Recipients used the fund to ensure that they were accompanied to hospital, GP, and physio appointments. One of the recipients is employed part time and indicated that it would not be possible to work without ILF. For another, attending the Glasgow School of Art to pursue a qualification in Photography and working with professional photographers who use the facility was made possible by ILF.
Having the confidence to volunteer and present to the City of Edinburgh Council on disability access issues are for one recipient indicators of the personal development outcomes facilitated by ILF. Feeling less dependent on family and friends was for all recipients an important enabler in maintaining healthy equal relationships with those closest to them.
The overarching theme to emerge from the consultation was that all recipients felt in control of their lives with a good balance between socialising, hobbies, education, volunteering, and employment. All appreciated the flexibility of ILF and derived confidence and belief from being able to manage the fund.
When asked to contemplate a scenario where they could no longer avail of the fund or if it was managed through a local authority or Health & Social Care Partnership (HSCP), losing independence and connection with their community was the spontaneous reaction of all recipients. Having to attend some form of daycare or perhaps live in supported or residential facilities was something that none could countenance at this time.
The differences between statutory care packages, Direct Payments and ILF from a lived experience perspective is poignantly captured in the following quotation from one recipient.
“The inflexibility of my care package means that I am up, washed and dressed at 8am daily irrespective of what my wishes are. Day centres are not for me and having ILF means I can structure the day around my voluntary work, attending meetings and catching up on administration. It would be a long boring and empty day without ILF. It gives me a purpose and makes me feel alive.”
5.0 Findings
There are some differences between Northern Ireland and Scotland which are relevant to this study. Firstly the value and reach of ILF is much greater in Scotland (£41,900,690 and 1995 recipients in 2022-23) than Northern Ireland (£6,850,000 and 349 recipients in 2022-23) There are five Health and Social Care Trusts (HSCTs) in Northern Ireland.
In Scotland Health and Social Care is managed by 31 Health and Social Care Partnerships (HSCPs) working towards a set of national health and wellbeing outcomes. All Partnerships are responsible for adult social care, adult primary health care and unscheduled adult hospital care. Many are also responsible for children’s services, homelessness, and criminal justice social work.
Northern Ireland has a more traditional daycare service than Scotland and it was felt by stakeholders that NI has a more established community infrastructure with over 8,000 community groups seeking to support the most vulnerable in society. The remote geography of the Scottish Highlands means that interventions which can reduce isolation and enhance inclusion and connectivity in these areas are valuable assets but can be difficult to service.
The consultations with ILF Scotland recipients/award managers reinforced similar outcomes accruing to those valued for ILF NI recipients in the 2019 and 2023 SROI studies. The combined influence of emotional wellbeing, health maintenance, sustaining natural support and relationships and having the capacity to ‘get on with life’ demonstrate a clear preventative effect as recipients are better positioned to manage and overcome challenges they encounter in daily life.
The feedback from recipients/award managers in both countries in respect of the challenges presented by Covid 19 was unerringly similar. Access to the fund was a critical enabler particularly for health maintenance, resilience, and emotional wellbeing throughout the pandemic. Those interviewed emphasised the competence of their PAs who worked effectively to ensure all public health guidelines were adhered to. When PAs had to self-isolate, ILF was able to meet the furlough costs.
None of the ILF Scotland recipients contracted Covid which meant that they avoided hospitals where the pandemic was most infectious. Those interviewed referred to the empathy, understanding and flexibility experienced in their correspondence with ILF during Covid.
5.1 SROI Results
The social value generated by ILF Scotland for a range of stakeholders demonstrates extended impact and value for money. ILF through its £40.9 million allocation to recipients in 2023 generated a social value of between £1:£12 and £1:£13. This is based on a Total Present Value of £493,329,593 created against the input of £41,900,000. The calculations applied financial proxies to twenty-one outcomes (See Appendix 1) for five material stakeholder groups evidenced through the primary and secondary research.
It is necessary to discount the values generated by each of the financial proxies used to reduce the risk of over claiming. It is evident from current statutory funding levels and policy priorities that equivalent levels of funding to the ILF allocation to support independent living in the community would not have been made available. We have therefore attributed low levels of deadweight 4 (5-10%) to the calculations.
There is no robust evidence base emerging that ILF has displaced other domiciliary or home-based services rather the contrary in that it has strengthened existing assistance and support requirements based on the principles of independent living. Reduced isolation, improved family relationships and increased capacity to contribute to their local community and wider society are among the outcomes reported by participants through their personal stories.
In the absence of ILF there would not have been sufficient community or voluntary services or inputs from family available to achieve similar outcomes for recipients. The SROI ratio is calculated over five years to reflect the longer-term impacts for stakeholders if the fund was no longer available. Given the complex needs of many recipients the drop off in impact would be in the range of 20-50% in years 2-5.
5.2 Sensitivity Analysis
Given that the analysis contains estimations and assumptions, it is prudent to review where these decisions have had a significant effect on the overall SROI calculation and to consider, therefore, the assurance that can be placed on such figures. However, as an evaluative analysis, the Study contains confirmed data regarding ILF funded outputs. The research makes extrapolated assumptions on the numbers impacted based on consultations with ILF Scotland recipients and aggregated data on outcomes from the NI study.
The sensitivity analysis explores the impact on the SROI ratio of changing some of the study’s key assumptions. Discount rates thought to be significant were amended to clarify the impact of changing attribution, deadweight, or displacement. Outcome values generated from research methods were adjusted to determine the impact of changing values, given that consultation results were extrapolated over the full stakeholder group. The sensitivity analysis did not significantly alter the final calculations which are considered assured.
6.0 Summary
Despite the differences in the scale and reach of ILF in Northern Ireland and Scotland, the social value generated by both funds for stakeholders is similar. This demonstrates that irrespective of geography, the core outcomes of emotional wellbeing, health maintenance, sustaining natural support and relationships and feeling independent builds resilience to manage and overcome challenges recipients encounter in daily life.
Appendix 1
Financial Proxies and sources used for the SROI calculations:
Relief from depression/anxiety (£40,442) HACT Social Value Bank
Sustaining full time employment (£14,433) HACT Social Value Bank
Belonging to a social group (£1,850) HACT Social Value Bank
Increased frequency of interaction with friends, relatives & neighbours- £7,750
Value of lives saved (£1,553,653)
Feeling in control of life (£15,894) HACT Social Value Bank
The average cost of residential care in Scotland (£39,656) Standard rates(Care Information Scotland)
Regular volunteering (£3,274) HACT Social Value Bank
Cost of a hospital stay - £483 per day Help with health costs (nhsinform.scot)
1 Undertaken by the Centre for Independent Living Northern Ireland & Gauge Impact. 2 Undertaken by Business Improvement Solutions. 3 (a) Given the small sample size of the ILF Scotland study, the final SROI value would be presented within an indicative value range (See Section 5) (b)The same stakeholders are impacted by ILF in Northern Ireland and Scotland and outcomes for the primary stakeholder (ILF recipients) are similar in both regions. 4 Deadweight is an estimation of the value that would have been created if ILF was not available to recipients.
Charter for Involvement Action Plan Update Summary 2023 to 2024
Summary of Progress 2023 to 2024
1. Background
The Charter for Involvement was developed by the National Involvement Network, supported by ARC Scotland. The Charter establishes how disabled people who use support services want to be involved and to have a say about the services they receive, the organisations that provide their services, and their wider communities.
2. Introduction
ILF Scotland signed up to the Charter for Involvement in 2018. We spent a considerable amount of time over several meetings with the Advisory and Stakeholder Groups to tailor the Charter Statements so that they were meaningful to our recipients, and we co-produced the Charter and Action Plan and published this in April 2021.
This report provides an update to the Board on the progress made during 2023 and 2024. We will update the Action Plan following the Board meeting and publish this on our website.
3. Key Progress
The focus of work to progress the Charter Actions during 2023 and 2024 has been in the three key areas of Self-Directed Support (SDS), Communication & Engagement and Corporate Governance.
SDS
Group members have been involved in discussions around improving information, communication, and processes at all stages of reviews. Specifically, exploring ways of ensuring that recipient choice and control continues to be central to review discussions and outcomes. Members have provided feedback on the role of the Award Manager and gaps in advice for example, employer commitment, PA recruitment and retention and the need for independent advocacy. They have provided suggestions for further staff training on specific areas integral to independent living and we are taking that on board.
Communication & Engagement
Group members attended staff training, development days, engagement events and Assessors attended / were involved in Group meetings.
The Stakeholder and Advisory Group Members sponsored the Social Return on Investment (SROI) Evaluations in Northern Ireland and Scotland in 2023 to 2024 to update the financial data and the feedback from recipients interviewed as part of the previous SROI in 2019. The findings show that for every £1 of ILF, there is a social investment saving of £13. This compares to just under £11 in 2019.
Members were fully consulted in the review and publication of external communications such as the new website, revised policies, newsletters, and letters to recipients with a focus on both content and accessibility. They contributed to the review of our complaints procedure and were jointly involved in all external consultations that ILF Scotland responded to in 2023 and 2024.
Members will be involved in the co-production of the revised Customer Feedback Strategy and in PR / Marketing campaigns by sharing their stories and raising the profile of disabled people and through this, promoting independent living.
Corporate Governance
There has been attendance by the Chairs of the Stakeholder and Advisory Groups at ILF Scotland Board meetings and recently the Chairperson of the board attended an Advisory Group meeting. Board members have an open invitation to attend any of the meetings.
Members of the Scottish Government Sponsor Team have also attended both the Advisory Group meetings in Scotland and the Stakeholder Group meetings in Northern Ireland.
Key information / decisions from Board meetings and Senior Management Team (SMT) meetings are shared at Group meetings and key issues from these meetings are discussed as a standard agenda item at SMT. ILF Scotland’s Senior Management Team members meet regularly with members of the Advisory and Stakeholder Groups to discuss relevant issues and work together on finding potential solutions.
4. Re-Opening of ILF in Scotland
The overall aim of the Charter is to ensure that recipients have a greater say and influence in the way that services are delivered. The Scotland Advisory Group has been instrumental in advocating for the re-opening of ILF to new applicants in Scotland from April 2024. The Chairperson of the Advisory Group is a member of the Re-Opening Co-Production Working Group and members of the Advisory Group participated in the re-opening co-production engagement events held across Scotland in 2023 and 2024.
This Group met with the Northern Ireland Stakeholder Group on 28 March 2024 for a joint meeting to discuss health and social care issues affecting disabled people in both countries and the role of ILF in that. Group members agreed to meet regularly in future to discuss joint issues and influence ILF Scotland’s response to this.
Both Group members then actively participated in an event in Scottish Parliament entitled ‘The Power of Independent Living’ where disabled recipients and other group members presented on the difference that ILF made to people’s lives. The event celebrated the re-opening of ILF to up to 1,000 new disabled applicants in 2024 and 2025. The Minister from Northern Ireland delivered a video address at the event and the Stakeholder Group will continue to work with the aim of achieving a similar re-opening of ILF in Northern Ireland.
5. Conclusion
We have made significant progress against the Action Plan during 2023 and 2024. However, it is important that this improvement work is ongoing and will continue throughout 2024 and 2025. The Charter has offered us a valuable opportunity to bring recipients, via the Advisory and Stakeholder Groups, closer together and has facilitated greater collaboration in service improvement and involvement in the organisation’s strategy, planning and delivery of services. This will continue as we seek to involve members in the co-production of our next strategic plan and in the ongoing development and improvement of our services.
Anti-Corruption and Bribery Policy
Created: 26 January 2016 Owner: HR Version: 2.0 Last Amendment Date: January 2022 Next Review Date: July 2024
Policy Statement
1. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships, wherever we operate, and implementing and enforcing effective systems to counter bribery.
2. We will uphold all laws relevant to countering bribery and corruption and we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct, both at home and abroad. The purpose of this policy is to:
set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption
provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.
3. Bribery and corruption are punishable for individuals by up to ten years' imprisonment. If we are found to have taken part in corruption, the Company could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. Therefore, we take our legal responsibilities very seriously, although we have not identified any particular risks for our business.
4. In this policy, third party means any individual or organisation you come into contact with during the course of your work for us. This includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
Who is Covered by the Policy?
5. This policy applies to all individuals working at all levels and grades. This includes senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as workers in this policy).
What is Bribery?
6. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
Gifts and Hospitality
7. This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. The giving or receipt of gifts is not prohibited, if the following requirements are met:
it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits
it complies with local law
it is given in our name, not in your name
it does not include cash or a cash equivalent (such as gift certificates or vouchers)
it is appropriate in the circumstances, for example, after a reassessment an individual may want to write a thank you card and give a box of chocolates
taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time
it is given openly, not secretly
gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of the Chief Operating Officer
8. We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered. However, as a public organisation our integrity, transparency and ethics should be of the highest standards possible.
What is Not Acceptable?
9. It is not acceptable for you (or someone on your behalf) to:
give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given
give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure
accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them
accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return
make or accept, facilitation payments or "kickbacks" of any kind
threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy
engage in any activity that might lead to a breach of this policy
Donations
10. We do not make contributions to political parties. We do not make charitable donations. No donation must be offered or made without the prior approval of the Chief Operating Officer.
Your Responsibilities
11. You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.
12. You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us or indicates to you that a gift or payment is required to secure their business.
13. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We also reserve our right to terminate our contractual relationship with other workers if they breach this policy.
Record-Keeping
14. We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
15. You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.
16. You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.
17. All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments.
How to Raise a Concern
18. You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with your line manager. Concerns should be reported by following the procedure set out in our Whistleblowing Policy.
Protection
19. Workers who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
20. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. 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 immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
Training and Communication
21. Training on this policy forms part of the induction process for all new workers. All existing workers will receive regular, relevant training on how to implement and adhere to this policy.
22. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
Who is Responsible for the Policy?
23. The Chief Executive has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
24. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.
Monitoring and Review
25. ILF Scotland will monitor and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption. This policy does not form part of any employee's contract of employment and it may be amended at any time.
Records and Data Sharing
26. We shall retain records of data and information obtained in relation to this policy, for so long as necessary in accordance with applicable law and our Data Retention Schedule. It may also be necessary for us to share your information with third parties, such as fraud or crime prevention agencies, depending on any issues raised under this policy.
Mainstreaming and Equality Outcomes Report - 2024 to 2026
Foreword
We are pleased to introduce our third Mainstreaming and Equality Outcomes Report. This document highlights the progress we have made in delivering our 2022 to 2024 equality outcomes. It also sets out our equality outcomes for 2024 to 2026 and the actions we will take to achieve them.
We aim to review our progress and planning relating to equality regularly and, as a minimum, to conduct a formal appraisal of our activities including our progress in achieving our mainstreaming equality objectives, on an annual basis.
This will provide an initial £9 million in the financial year 2024 to 2025, enabling up to 1,000 additional disabled people with the most complex needs to access the support they need to live independent lives.
To prepare for the re-opening for new applications in April 2024, ILF Scotland staff are collaborating with disabled people, their representative organisations, the Scottish Government and other key stakeholders on the co-production of the re-opened fund.
Through this important work, we wish to continue to operate high quality and efficient services to reach more recipients and overall to better enable independent living for disabled people and those with long-term health conditions.
However, it is our day-to-day activities that demonstrate our commitment to mainstreaming equality on a continual basis. Equality is at the heart of what we do as an organisation and runs through all our activities, thoughts, behaviours and plans.
Our Board and staff group are diverse with regards to their own lived experience and they are also well-informed about equality, diversity and inclusion on a broader basis. We always strive to further improve our practice and therefore we continue to build upon the work carried out to date. We continue to look for ways we can listen to, learn from and provide better informed services relating to equality, diversity and inclusion to our recipients, our staff and our other key stakeholders. Where there is challenge in delivery, we will seek to turn this into an opportunity to improve what we do.
The organisation does not operate in isolation and continues to seek out best practice, feedback, reporting tools, partnership working and latest ideas.
As well as addressing inequality in relation to protected characteristics, we are also considerate of broader definitions of diversity that focus on additional areas, such as neurodiversity, cognitive diversity, social mobility and socio-economic diversity. The need to consider the intersectionality and the impact of how a combination or more than one protected characteristic can perpetuate different forms of discrimination or inclusion challenges, is also paramount.
Our plans are informed by a consideration of the existing context, as well as anticipated future impacts, such as the increase in the use of AI technologies and increased regulatory interest in identifying meaningful diversity metrics. We also look to incorporate best practice and guidance such as the UK Government’s Disability Action Plan and Inclusive Britain action plan and policy commitments (DLUHC and Race Disparity Unit, 2022)
ILF Scotland operates as a discretionary fund providing financial awards to approximately 2,243 disabled people in Scotland and Northern Ireland to help them live independently. This includes the newly re-opened Independent Living Fund, which provides a regular 4-weekly award to enable individuals to pay for support so that they can live with choice, control and dignity in their homes and within their local communities.
In addition, the ILF Scotland Transition Fund provides one-off grant funding for young disabled people aged 16 to 25 years to help them to increase their independence and participate in their communities.
ILF Scotland employs:
81 people (3 on temporary contracts): a team of 3 in Northern Ireland and 78 across Scotland, including 51 support staff in the Livingston office and 30 home-based assessors. We actively recruit colleagues who are disabled and who have long-term health conditions. In addition, we have 8 Board members, 4 of whom identify as disabled.
Legal Framework
The Equality Act 2010 sets out the ‘general equality duty’ for all public authorities to have due regard to the need to:
Eliminate unlawful discrimination, harassment and victimisation and other prohibited conduct.
Advance equality of opportunity between people who share a relevant protected characteristic and those who do not, particularly by removing or minimising disadvantage; meeting the needs of particular groups that are different from the needs of others; and encouraging participation in public life.
Foster good relations between people who share a protected characteristic and those who do not.
The Equality Act 2010 lists nine protected characteristics:
Age
Disability
Gender Reassignment
Marriage and Civil Partnership
Pregnancy and Maternity
Race
Religion or Belief
Sex
Sexual Orientation
and defines direct and indirect discrimination as:
“Where someone is treated less favourably according to a protected characteristic or could be disadvantaged compared to someone who does not share that protected characteristic.”
All people are entitled to equal treatment and the way in which people are treated shapes their lives and lived experiences. It is important that we recognise and understand how unequal treatment under each characteristic impacts on people and particularly those who are living with more than one or multiple protected characteristics.
Regulation 4 of the specific equality duties requires that we base our Equality Outcomes on evidence and involvement of equality groups.
The The Equality and Human Rights Commission (EHRC) regulate performance against public sector equality duties. From April 2020, ILF Scotland is required to report on the areas outlined below, every two years, apart from the Statement on Equal Pay, which is every four years. We also have a duty to publish diversity information about our board members. This report meets our general and specific duties under the Equality Act 2010 and outlines:
Mainstreaming equality and diversity is a long-term, strategic approach to ensure that equality, diversity and inclusion is truly integrated and sits at the heart of organisational culture and strategic and operational delivery.
It takes time and resources to develop this properly and it needs the commitment, encouragement and support of our Board and our Senior Management Team (SMT) to make sure that every member of our staff understands, accepts and embraces equality across every part of our organisation and in the services we deliver to our recipients. We believe that mainstreaming equality has many benefits including helping us to:
put equality at the heart of everything we do
embrace diversity across our organisation and attract and retain a motivated workforce, rich in talent, skills and experiences
continually improve our service delivery and make sure our services meet the diverse needs of our recipients
help us to be more socially inclusive and engage better with those most excluded in society
improve our performance
help us to deliver our Strategic Plan ‘Hope & Ambition’ and our associated Delivery Plan
We strongly embrace the principles of equality and are proud of the journey we have taken so far.
We became a Non-Departmental Public Body (NDPB) in 2018 and since then there have been changes to the wider equality context in which we work. These include legislative changes, the impact of major events and societal changes bringing certain inequalities into the foreground.
Key examples to note include:
Legislation Milestones:
The Gender Representation on Public Boards (Scotland) Act 2018 encourages Public Bodies to achieve at least 50% representation of women on their Boards.
Civil Partnership (Scotland) Act 2020 enables people of different sexes to be in civil partnerships, a right that was previously only available for same sex couples (and had been introduced before same sex marriage was an option for same sex couples).
Ongoing debate and legal action to clarify the definition of sex in law and attempts to reform the Gender Recognition Act in Scotland in 2023 have increased awareness of the experiences of transgender people.
The Scottish Government has now committed to introducing a new human rights Bill for Scotland. This will incorporate United Nations (UN) human rights treaties of:
International Covenant on Economic, Social and Cultural Rights (ICESCR)
Convention on the Elimination of All Forms of Discrimination against Women (CEDAW)
International Convention on the Elimination of All Forms of Racial Discrimination (CERD)
Convention on the Rights of Persons with Disabilities (CRPD).
The new Bill will also include the right to a healthy environment, as well as rights for older people and LGBTQI+, which includes lesbian, gay, bisexual, transgender, queer (or questioning), and intersex people.
Key Events and Societal Changes
The UK’s departure from the European Union in January 2020 and the current Scottish Government’s pledge to become independent and apply to rejoin the EU has meant that the context we operate in is open to significant change.
The COVID-19 pandemic drew further attention to societal inequalities with women, disabled people, and ethnic minority groups disproportionately impacted by the effects of the virus and of lockdown measures. The pandemic has also changed the way we work and live, with more homeworking and reliance on digital technologies.
Events such as George Floyd’s murder; the exposure of sexual harassment cases; and high-profile murder cases demonstrating violence against women, together with the resulting impact of the #MeToo and #BlackLivesMatter movements, have all brought societal and workplace inequality into the foreground.
Population growth in Scotland has been driven by international migration and migration from elsewhere in the UK together with changes in birth and death rates.
The cost-of-living crisis is widening inequality and disproportionately affecting those who are most vulnerable in society.
All of the above has informed a shift in how we think about inequality and how we look to achieve inclusion in how we operate.
Our funding helps our recipients to access the same opportunities as others and achieve their personal independent living outcomes. We continuously review our strategies, plans, policies and practice to provide the best service we can.
Here you can find out more about our work from some of our recipients:
We regularly engage with our recipients. Here are some of the highlights of what we do:
1. As part of ILF Scotland’s ethos and aim to work in co-production with our recipients, we have established a Scotland Advisory Group.
The purpose of this group is to support the improvement and development of ILF Scotland, for recipients living in Scotland, by advising on all matters relating to the operation of the fund, including:
experiences of using the existing fund
experiences of communicating and interacting with ILF Scotland
insight and advice into potential policy developments relating to the existing fund
content and accessibility of ILF Scotland publications
any other relevant matters
The Advisory Group reports to the ILF Scotland SMT, who in turn report learning and outcomes from the group to the Board and the Scottish Government, as required.
2. As part of the re-opening of the Independent Living Fund, we held a series of co-production in person and online engagement events across Scotland to seek the views of disabled people, their carers and representatives and other key stakeholders.
Our Staff
We are a close team and we regularly listen to what staff have to say both informally and using regular survey tools.
On our website there are two case studies from members of our staff to hear from them directly.
Equality Assessment
We carry out Equality Impact Assessments (EQIAs) when we develop our external policies and publish these on our website. We continue to work to extend EQIAs across all our service delivery areas, as well as internal polices, plans and projects too.
For example, when developing our retirement policy, we ensured that an EQIA was conducted using our impact assessment tool, linking directly with our screening assessment plan. We were therefore able to consider the potential impact of this policy whilst screening for relevance and proportionality.
We believe in the many advantages of conducting EQIAs, in addition to adhering with our statutory duty to do so, including:
enshrining the rights of disabled people to being treated with dignity and respect and being able to exercise choice and control in living their lives
systematically conducting Equality Impact Assessments early in the planning process ensures that we identify any barriers that we need to avoid or mitigate as part of our decision making
going through the EQIA process makes sure that we think about how the consequences of our plans and decisions might affect people with protected characteristics, other than disability, ensuring that different groups are included
ensuring that we gather relevant information to demonstrate that our decisions are based on evidence, which is important in the event of challenge
We have raised awareness and provided training across the organisation of our impact assessment tool and screening assessment plan, taking staff through relevant worked examples of EQIAs on live work-related topics. We will repeat this training in 2024 to 2025 along with further examples to embed this area further in future, which will enable us to apply good equality practice across the organisation.
Key partners in our approach to equality include the Scottish Government and the Non-Departmental Public Body Human Resources network and forum where core Scottish Government and other Public Bodies share best practice on equality and diversity policy and practice.
In addition, we have developed ongoing positive working relationships with ARC Scotland, Who Cares? Scotland, a range of Person-Centred Planners and other partners via our continued engagement at events and meetings. This ensures that we keep equality at the heart of any decisions we make regarding the services we provide to young disabled people through our Transition Fund. We also signpost disabled people to other sources of support, such as Scottish Welfare Fund, other charities, benefits agencies / advisory organisations as appropriate.
We value the important input of our Advisory and Stakeholder group members in Scotland and Northern Ireland for the input and feedback they provide on equality when we work with them to develop the Charter for Involvement and through co-production on our strategies and policies. The Charter fits with human rights legislation, specifically the United Nations Convention of the Rights of Disabled Persons. Implementing the Charter actions, co-produced by the Advisory and Stakeholder Groups, helps ensure that we listen to our disabled recipients and their representatives so that they remain at the heart of our decision making.
We continue to embrace ways to work in partnership to improve our services and approach.
Report on Progress on Equality Outcomes for 2022 to 2024
We set ourselves ambitious equality outcomes and these will be considered in the next section of this report.
Some of our Key Equality Achievements:
The Equality Committee, chaired by our CEO, is attended by a good representation of members of staff from across the organisation, with additional support and guidance from one of our Board members. The work of this committee is instrumental in driving our performance in achieving our equality outcomes.
Integrated suggestions and ideas from the Minority Ethnic Recruitment Toolkit to improve the diversity of our workforce. For instance, we have worked on our website to make this a more welcoming experience and have advertised on the radio to enhance the reach of our advertising.
In addition, we raised awareness with our staff and recipients of the ‘Now Hear Me’ campaign, aimed at helping people to understand the needs of individuals who may have difficulties as a result of impaired or no speech and who use Augmentative and Alternative communication (AAC).
In December 2022, we were named as one of the Top 10 Family Friendly Employers in the UK (for the fourth time).
In June 2023, we achieved our sixth year as a Top 30 Employer with Working Families.
Winning the ‘Aligning Local Services Category’ and a finalist for the ‘Excellence in Governance and Risk Management’ category of the Public Finance Awards 2023.
Progress in Relation to Objectives set for 2022 to 2024
Our Equality Objectives were integrated into our business plan as Specific, Measurable, Achievable, Realistic and Timebound (SMART).
Objective: Equality Impact Assessment is consistently applied across the organisation
We made progress in further embedding the use of Equality Impact Assessments in our business practices. EQIAs are used in all policy changes across both the Independent Living Fund and the Transition Fund as standard practice and we have completed EQIAs for the re-opened policy changes as required. We have expanded EQIA completion across other areas of the business, but we still have more work to do to ensure consistency of practice across all of the organisation. We have developed an EQIA prompt in our project planning tool to assist with EQIA awareness.
We will focus on developing further training and awareness for all ILF Scotland staff during 2024 to 2026.
Objective: The Transition Fund has an appropriate reach across all eligible disabled young people in Scotland.
We carried out targeted work in key geographical areas of recognised deprivation and underrepresentation, working with corporate partners within these areas, which helped to increase the uptake in applications from groups that have been traditionally more difficult to engage with. This work also included the deaf community and care-experienced people as outlined in our Corporate Parenting Plan.
The Transition Fund has grown by 40% in 2022 to 2023 compared with the number of applications received in 2021 to 2022 and by 26% in 2023 to 2024 compared to 2022 to 2023. The drop in numbers is due to no repeat applications being allowed in the last quarter of 2023 to 2024. The new policy now limits applications to one per person, rather than repeat applications. While this does reduce accessibility for repeat applications, it is intended to increase the reach of the Transition Fund across a larger number of individual applicants.
Given the continued increasing demand for the Transition Fund, we will focus our engagement work this year on targeting those areas in the community that are most difficult to reach, reaching out to partners already operating and engaging with young people who might benefit most from the fund.
Objective: ILF Scotland’s activities are informed by a proactive approach to mainstreaming equality, based on a programme of continuous improvement and co-, production, internally and externally.
One example of our approach has been establishing the Co-Production Working Group to prepare for the re-opening of the Independent Living Fund (ILF), announced by the First Minister in September 2023 as part of Scotland’s Programme for Government. This group includes disabled people, carers, disabled people's organisations (DPOs) and representatives of ILF Scotland, the Scottish Government and health and social care statutory partners. Regular meetings of this group, combined with external engagement events, ensured that we proactively took on board the views of disabled people and their representatives in developing the policy framework for the re-opened ILF for Ministerial approval. Members of this group commented that the nature of the engagement work we undertook for the re-opening of the fund was reflective of a true co-production process and that it should be regarded as an example of good practice. We will continue to work with this group to engage further with disabled people to make additional improvements to accessing ILF during 2024 and 2025.
Our Equality and Diversity Committee has informed our annual staff survey and our recruitment and succession plans, with work continuing to ensure our programmes of learning and development offers equal opportunity.
Objective: Our services are targeted and appropriately tailored to our customers with one or more protected characteristics, taking account of those from a disadvantaged socio-economic background.
For the Transition Fund, we targeted via local media, paid social media and other forms of marketing, those geographical local authority areas that were under-represented in terms of applications to the fund. This ensured that disabled young people in those areas were given an equal opportunity to apply.
To maximise income, our assessors provide basic welfare benefit checks and refer to specialist welfare benefit and debt advice support where required. They also act in an advocacy role at times and often refer to independent advocacy services and to a range of other disability support organisations.
We have improved our ongoing service delivery in response to feedback from the COVID-19 recipient feedback survey. We developed an action plan following the analysis of the recipient feedback survey responses and implemented this in full.
Objective: We provide comprehensive monitoring and reporting on protected characteristics in line with good practice guidance.
We have not pursued this objective as we are awaiting the revised guidance from the Scottish Government. We will address this at an appropriate time in the future.
Objective: Our Communications Strategy appropriately reaches those people with protected characteristics and commits to ensuring improved access across our services and information.
This has been completed.
Our Communications and Engagement Strategy commits to reaching people with protected characteristics, ensuring improved information and access to our services.
For new applications, we have a communications and engagement strategy that works with people from ethnic minority groups to ensure representative applications.
For the Transition Fund specifically, we have used local media, paid social media and other forms of targeted marketing to reach geographical areas with the lowest uptake and areas of deprivation.
Members of the Ambassadors Group have helped us at targeted events and engagement sessions to help those with protected characteristics apply to the Transition Fund.
We actively target disabled young people from the most deprived backgrounds by targeting in person engagement towards schools and groups within the areas of the highest deprivation.
While not yet a protected characteristic, we also target young people whose experience of the care system has had a lasting, disabling effect on their ability to be able to make their way in the adult world. We do this by actively engaging with those organisations that work with these young people such as fostering and adoption agencies, local authority Throughcare and Aftercare Teams and support organisations such as Who Cares? Scotland.
In addition, during Care Experienced Week 2023, we worked with a TF recipient who is care experienced to showcase and promote how the TF can support care experienced young people. This recipient wrote a blog called ‘Who Cares? Scotland’s youngest trustee Eireann on Care Experienced Week 2023 and shared her story on social media.
Objective: We work with, learn from and benchmark with similar public authorities to help us to promote equality in a wider context.
We made initial contact in 2023 to 2024 with Equality Leads across the Scottish Government and other Public Sector organisations. We would have liked to have made greater progress but were constrained by the volume of business priorities elsewhere within ILF Scotland. We will continue to build these relationships through our involvement with organisations as capacity allows.
Objective: Our workforce is diverse and representative of the communities we serve.
We continued to drive forward our ability to attract diverse talent to ILF Scotland through our approach to recruitment from ensuring our equality objectives were part of our procurement, search, engagement and appointment processes. Whilst a candidate market, it is noted that the volume and diversity of interest in our vacancies demonstrated our success in achieving this with the candidates appointed enhancing our already diverse workforce.
Moving forward, we will remain focussed on this where there are opportunities to grow. In addition, we will continue to look inwards in terms of our ways of working, striving to do better, ensuring we are person and life centred, flexible in our approach to how people work and focussed on health and wellbeing objectives for our staff. As well, we will continue to empower and improve staff resilience through training and support as they continue to support disabled people across Scotland and Northern Ireland to live independently.
Objective: To introduce an Employee Passport Scheme
This has been completed.
To support colleagues with challenging personal circumstances, or with a disability, impairment or long-term health condition, we introduced a voluntary Employee Passport Scheme, which facilitates discussion with their line managers around necessary adjustments to work / workspaces.
Almost all of us will have circumstances, health conditions or commitments that impact our work at some point in our career. The introduction of a voluntary employee passport provides a framework for individuals to have a discussion with their line manager about their personal circumstances with a view to agreeing adjustments to support the employee to be their best in the workplace and beyond.
We also offered a well-being hour and in our 2023 employee engagement survey, 77.6% staff members stated that they welcome and use this. Following on from the 2022 to 2024 report, we have improved our non-contracted wellbeing hour offering by implementing a contracted 35-hour working week (FTE was previously 37 hours) from 1 April 2024. This offering to all colleagues is an overall reduction (pro-rated) of two hours with no reduction in salary. Our staff well-being continues to be front and centre of our decision making across the organisation. We plan to gauge staff feedback through our next Staff Survey in 2024.
We committed to continue to develop ILF Scotland as an inclusive and supportive workplace where everyone can contribute to the best of their abilities ensuring our workforce is as diverse and representative of the communities we serve.
Summary
We achieved many positive outcomes over the period of the last plan. In the latter part of the year, however, through necessity, we were required to prioritise the work needed to achieve the re-opening of ILF Scotland in April 2024, which was announced as part of the Programme for Government in September 2023. Therefore, progress across all our intended outcomes has perhaps been a little less than we anticipated. We have identified a more manageable number of outcomes for this current 2024 to 2026 plan to allow us to continue the development of the fund. Our Equality and Diversity Committee will hold regular meetings throughout 2024 to 2026.
We plan to undertake further work to our forms and systems to provide better equality data on protected characteristics across both funds to improve our monitoring and reporting practices in line with good practice.
ILF Scotland remains committed to embedding equality outcomes and will pursue further expansion and improvement on our approach to working in partnership with others to promote equality in Scotland.
Board Diversity Duty
The Gender Representation on Public Boards (Scotland) Act 2018 sets an objective for public boards that they have 50% of non-executive members who are women.
ILF Scotland has worked proactively with the Scottish Government for a number of years to improve the diversity and gender balance of the ILF Scotland Board.
We have achieved greater than 50% female representation on our non-executive Board since 2015 and have sustained this position through to 2024, with 75% of board members being female.
We measure the representativeness of our Board on an ongoing basis.
We conducted an equality monitoring exercise with our Board and workforce in 2021, which has informed our future recruitment planning to ensure an even more diverse and equitable Board. People from ethnic minority groups are currently underrepresented on our Board.
Part time working pattern remains predominate toward women.
During 2023, 100% of staff worked within our hybrid working offering, with employee choice and control over whether they are working in the office or at home.
We used data capture and analysis to measure the representativeness of our workforce profile and use this information to identify improvement measures such as targeted recruitment.
The accuracy of our equality profile data is important as it can assist our Board and SMT to plan the workforce of the future and provides for the potential justification of allowable positive action to make improvements, leading to a workforce that reflects the population and geographical locations we work in.
Our workforce monitoring data indicates that we still have room for improvement in increasing the representation of disabled people and people from ethnic minority populations in our workforce. Our organisational demography by the end of Q4 2023 to 2024 was (78) and Directors (8).
Women are well represented in the general workforce and at managerial level: 78%:22% female: male. Women are underrepresented at Director / Senior Management Team Level.
We plan to address this through leadership / management development, succession planning and future recruitment to senior posts during 2024.
We have a good representation of disabled people with 20.2% self-identifying as disabled. As a comparison, in September 2023 the Scottish Government reported 8.7% of staff were disabled.
We have some representation of employees from ethnic minority groups employees from ethnic minority groups - 2.2%, a decrease from our previous representation of 4.10%. In September 2023, for comparison, the Scottish Government reported a figure of 2.9%.
The information we have on sexual orientation and gender reassignment is that 1.1% of staff identify as LGBTQI+. In September 2023, the Scottish Government reported a figure of 6.0%.
Data on the current workforce within ILF Scotland is robust in terms of age and sex. Data on the protected characteristics of ethnicity, disability, religion and belief, sexual orientation and gender reassignment continues to be limited due to the numbers of staff leaving questions unanswered during staff surveys or stating they would prefer not to answer.
Work continues to increase awareness throughout our workforce of the benefits of disclosing protected characteristic data as well as reassuring staff that this information is confidential.
As a positive measure in recruitment, we specifically encourage applicants with protected characteristics to apply for job vacancies. We are not alone in trying to meet the challenge of a representative workforce and this will continue to be a key focus of activity.
The findings from our 2023 employee engagement surveys indicate (88% response rate):
100% of our staff can and do continue to work flexibly and remotely.
Life / Balance Opportunities: 96.6% stated that they were in control of this ‘most of the time’.
77.6% of staff members welcome and use the Well-Being Hour.
100% of our staff who responded stated that ILF Scotland is a good employer.
These are the draft new Outcomes for 2024 to 2026. ILF Scotland staff and Advisory, Stakeholder and Young Ambassadors group members have been consulted on these. They have gone to the ILF Scotland Equality Committee and SMT for sign off and then to the Remuneration Committee for information and the Board for final approval. They will be integrated as SMART objectives into our business plan.
Outcome 1: Integrated Equality Impact Assessments
Integrated Impact Assessments are consistently applied across the organisation with a commitment to have our staff members appropriately trained and our board members fully aware of this.
Action: Further embed the use of Equality Impact Screening and Assessment practices across all business functions by providing additional awareness and practice training to Managers by the end of 2024 to 2025.
Outcome 2: Promote Neuro Inclusion
To start the neuro inclusion journey within ILF Scotland focused on developing a neuro inclusive culture with the aim of creating even greater comfort and belonging for our diverse staff group.
Action: Raise awareness of neurodiversity and provide staff training to cover this area specifically as part of our equality and diversity training. Provide more detailed training to front line staff working in the Transition Fund so that they can provide and informed customer service to young people who are neurodivergent.
Outcome 3: Corporate Parenting
More young disabled people who are care experienced are aware of the Transition Fund and how to apply and our staff and Board members are aware of the Transition Fund and how it might positively impact care experienced young people.
Action: Through our Corporate Parenting Plan, we will further develop our communications strategy to target care experienced young people and those that support them to ensure they are aware of the Transition Fund. We will ensure ILF Scotland staff and Board Members are aware of the principles of Corporate Parenting through training courses and induction programmes.
Outcome 4: ILF Re-Opening
Following an announcement by the First Minister in September 2023, the Independent Living Fund, closed to new applications since 2010, re-opened to new applicants in April 2024. This will enable up to 1,000 additional disabled people with the most complex needs to access the support they need and deserve to live independent lives.
A Co-Production Working Group was established in October 2023, consisting of disabled people, carers, disabled people's organisations (DPOs) and representatives of ILF Scotland, the Scottish Government and health and social care statutory partners. A range of engagement events were held to seek views on the policy framework for the re-opened fund. A commitment was given to continue to develop policy in 2024 to 2025.
Action: Facilitate meetings of the Co-production Working Group every two months in 2024 to 2025, with the first meeting to be scheduled for June 2024. Report on learning from the first two months of receiving applications to the re-opened fund and work together with the group and others as required to further develop policies around the key issues raised by disabled people and others at the re-opening engagement events. Arrange further co-production opportunities with our recipients and others as part of our strategic planning consultations in the latter part of 2024 to 2025.
These equality outcomes will guide our progress and direction, which will be monitored by our Equality Committee. We will develop action plans and monitor and review these annually to ensure we remain on track and will update progress annually as well as updating plans with any relevant information due to unplanned and / or unforeseen national and international events.
Conclusion
We have always set equality outcomes with the intention that we truly embed equality, diversity and inclusion into our strategic and annual delivery plans and our daily activities. While we have not been able to achieve everything we set out to do, we recognise that we have still progressed and we remain committed to continue our equality journey.
Our Equality outcomes are co-produced through the work we do to engage with and listen to our recipients and our staff, then formally set by and approved by our Board. Board members provide the necessary scrutiny to ensure that we meet our duties and consider potential equality impacts as part of our corporate decision-making.
Our SMT shares responsibility for promoting and embedding equality in our plans, projects and operational processes.
Each employee also has an individual responsibility for considering equality issues in all areas of the work we do and in working with others to continually enhance our processes.
We will continue to instigate and implement innovative ways to understand the needs of our recipients, listening and working hard, to learn and improve what we do.
We will use the employee equality metrics in this report together with developing best practice, to support and inform our recruitment and employment practices, to improve our workforce equality and diversity and to promote the organisation as an employer of choice.
As a Non-Departmental Public Body, we ultimately aspire to continue to work in partnership with the Scottish Government and other Public Bodies, to be an inclusive employer and to continue to enhance the access to our services and the support provided to disabled people in Scotland and Northern Ireland.
Appendix I: Equal Pay Gap Information
We report our pay gaps using a single measure, by comparing the average full-time equivalent earnings in 2023 to 2024 by gender. For example, the full-time gender pay gap compares the mean and median hourly pay, excluding overtime, of men and women. It is important to note that a pay gap does not necessarily mean a difference in pay for comparable jobs or work of equal value.
Gender Pay Gap by Grade
Administration
Grade A3 Female pay as a percentage of male pay: not applicable Median Pay Gap: 0% Mean Pay Gap: 0%
Grade A4 Female pay as a percentage of male pay: not applicable Median Pay Gap: 0% Mean Pay Gap: 0%
Specialist Professional and Technical
Grade B1 Female pay as a percentage of male pay: 95.71% Median Pay Gap: 4.67% Mean Pay Gap: 4.27%
Grade B2 Female pay as a percentage of male pay: 99.92% Median Pay Gap: 0% Mean Pay Gap: 0.09%
Grade B3 Female pay as a percentage of male pay: 95.49% Median Pay Gap: 0% Mean Pay Gap: 3.77%
Senior Management Team (SMT)
Grade C1 Female pay as a percentage of male pay: 100% Median Pay Gap: 0% Mean Pay Gap: 0%
Grade C2 Female pay as a percentage of male pay: 100% Median Pay Gap: 0% Mean Pay Gap: 0%
Grade C3 Female pay as a percentage of male pay: not applicable Median Pay Gap: 0% Mean Pay Gap: 0%
CEO
Grade SCS 1 Female pay as a percentage of male pay: not applicable Median Pay Gap: 0% Mean Pay Gap: 0%
All comparable jobs or work of equal value are paid on the same scale. The pay gap in 2023 to 2024 is entirely due to spinal placement on the grade and will even out as employees reach the top of their scale.
This is set out in table form below.
Gender Pay Gap by Grade
Job Type
Grade
Female pay as a percentage of male pay
Median Pay Gap
Mean Pay Gap
Administration
A3
n/a
0%
0%
Administration
A4
n/a
0%
0%
Specialist Professional and Technical
B1
95.71%
4.67%
4.27%
Specialist Professional and Technical
B2
99.92%
0%
0.09%
Specialist Professional and Technical
B3
95.49%
0%
3.77%
SMT
C1
100%
0%
0%
SMT
C2
100%
0%
0%
SMT
C3
n/a
0%
0%
CEO
SCS 1
n/a
0%
0%
Where men and women are undertaking work of equal value, they are paid a similar hourly rate and consequently the gender pay gap is low.
Appendix II: Equal Pay Statement
This Equal Pay Statement outlines ILF Scotland’s support for the principle of equal opportunities in employment.
ILF Scotland is committed to the principles of equality of opportunity in employment and believes that staff should receive equal pay for the same or broadly similar work, or work rated as equivalent and for work of equal value. This will be regardless of their age, disability, ethnicity or race, gender reassignment, marital or civil partnership status, pregnancy, political beliefs, religion or belief, sex or sexual orientation.
To achieve this, we will operate pay and progression systems that are transparent, based on objective criteria and free from unlawful bias.