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COVID Vaccine Certification

Letter from Deputy First Minister and Cabinet Secretary for COVID Recovery, Scottish Government to the Convener on 28 October 2021

Dear Siobhian,

I am writing in response to your letter of 30 September about Covid Vaccine Certification, in which you asked for further information on three specific topics

Monitoring implementation

As you know, the Scottish Government published the Covid Vaccine Certification Evidence Paper on 29 September and I wrote to the Committee that morning to share an advance copy. This paper sets out the wide ranging and balanced evidence available in relation to Certification, and was used to inform our decision to proceed with the scheme.

The purpose of the scheme and outcomes are set out in the Coronavirus (COVID-19): mandatory Vaccine Certification proposals of the 9 September and the Coronavirus (COVID-19): Vaccine Certification update of the 23 September. The policy objectives of the scheme are four-fold:

• Reduce the risk of transmission of Coronavirus
• Reduce the risk of serious illness and death thereby alleviating current and future pressure on the National Health Service
• Allow higher risk settings to continue to operate as an alternative to closure or more restrictive measures
• Increase vaccine uptake

Throughout the pandemic we have taken a rounded view of restrictions. In line with the Covid legislation we are required to review the regulations every three weeks, and they must only remain in place whilst they are necessary and proportionate. As the Committee will be aware, the last review was on 26 October and was reported to Parliament on that date. The next reviews are scheduled for 16 November and 7 December. We look at a range of data to determine whether the regulations continue to be required. This includes the current state of the pandemic, the trends, and anticipated pressures such as winter and potential surges in infection arising from, for example, COP26 and the forthcoming festive season. Certification will be considered as part of that review.

In addition, we are committed to monitoring the impact of the scheme across the aims, and have considered carefully your helpful proposals on indicators which could be used to assess the scheme as part of the three weekly review process. Unfortunately, due to data protection and GDPR legislation as well as the unavailability of some data, we are not able to provide all the information you have suggested for each indicator. The table at Annex A summarises the position with regard to the Committee’s request.

Understanding the effects of the scheme, and how it is being implemented, requires data about the use of the technology, vaccinations, and the impact on society and the economy.  However, it is challenging to isolate the effects of any one element of the Covid response.  Some of this information about app use, vaccination and case trends is available through the PHS and Four Harms Dashboards, and formed the basis of the three-weekly review. We are in the process of developing data and operational insight and intelligence that will help us to address your questions and will give you further information as this work evolves.

Public communication and engagement 

As the Committee highlighted, a proactive public information and community engagement strategy which enables the public to understand the purpose of the scheme and how to use it, is required to accompany the implementation of Certification.

A national advertising campaign is running across radio and digital advertising formats to increase awareness of domestic Certification. This signposts to nhsinform.scot for more information and promotes downloading the NHS Scotland COVID Status app. Further communications activity has been delivered through Scottish Government social media accounts and media relations activity at key stages from the initial announcement on the introduction of domestic Certification.

The communications approach for domestic Certification at a community level was to go through the venues and events impacted. The Domestic Certification Stakeholder Toolkit has been circulated to the following groups: Local Authority Communications Teams; Health Boards; Economic Recovery Hub; DFM COVID Recovery Group; COVID Business Support and Strategic Engagement Team. This contains various assets which can be used by stakeholders to promote domestic Certification through their communication channels.

We are building on learning across other materials, such as the Covid-19 Vaccine Explainer animations, and are currently developing a Covid Certification Summary Information Sheet which will include key messages and guidance on how to access translated information about Covid Certification. This Information Sheet will signpost people to the information on NHS Inform for further detail.

This Summary Sheet takes into account conversations with minority ethnic and seldom heard audiences and will address their specific concerns, such as data collection, usage and privacy. The Summary Information Sheet will be created in multiple languages and accessible formats.

The impact of the marketing activity will be assessed through the Scottish Government campaign tracking. We also have access to information from digital advertising to identify the reach (how often the adverts have been delivered) and impact (how the percentage taking action relating to one of the campaign adverts compares to other Scottish Government campaigns and benchmarks used by our media buying agency).

Winter plan, timing and consultation

The COVID-19: Strategic Framework series provides an important overview and explanation of our management of the epidemic. The June update set out the approach for moving to the current position of a largely vaccinated population with a small number of residual baseline measures to keep the virus controlled. We plan to publish a further update of the Strategic Framework shortly, which will explain our approach to managing the pandemic over the late autumn/winter period.

Our expectation is that COVID-19 will become endemic and that we have a difficult winter to plan for. Factors such as vaccine uptake and vaccine waning, levels of compliance and the risk of new variants can all combine in different ways to produce very different outcomes requiring different responses. 

There are potential scenarios in which further targeted and proportionate interventions would again be required, on a temporary basis, to control the virus. We hope that these scenarios – such as a new variant of concern that is worse than, and replaces, the now dominant Delta variant – do not become the reality, but we need to be ready in case they do. We already have our system of protective levels of gradated restrictions, which would enable us to respond in a targeted and proportionate way, potentially tailored by geography, in response to epidemiological conditions. Alternatively, we might pursue specific measures on certain high-transmission risk settings that avoided the need for a more general levels approach and thereby alleviated broader harms. This could potentially include extending Certification to a wider range of settings. We will always take current and anticipated epidemiological conditions (across a range of measures) into consideration when determining the appropriate response, to ensure that it is necessary and proportionate.

It is worth reiterating that we are not wholly reliant on restrictions to control the virus, and we would continue to take action across multiple fronts to reduce the need to re-impose restrictions, as we are well aware of the broader harms that they cause. For example, increased adherence to the existing measures in place would tend to reduce the need for restrictions, and we would encourage all inviduals and organisations to continue their efforts on this front.

We want people and organisations to be assured that we will be ready to respond effectively should the epidemiological conditions require that. However, the re-imposition of restrictions remains a contingency that we hope not to have to deploy. More specifically, in terms of how long Certification might be in place, under the legislation it can only remain in place where the evidence and clinical advice indicates that it remains proportionate and necessary. It is not possible to set those out definitively; as set out above it will depend on a combination of measures for example, case rates, pressure on the NHS, vaccination rates and impact on businesses. Suffice to say we do not want to keep the scheme for any longer than is necessary

I hope that the Committee finds this further information helpful.

Yours sincerely,

John Swinney
Deputy First Minister and Cabinet Secretary for COVID Recovery,
Scottish Government