Digital licencing - New Private Sewage Treatment System

Digital licencing - New Private Sewage Treatment System (PSTS)

22/11/2023

Principle product owner (15/07/2024)

Head of function (permitting) (15/07/2024)

Yes - a DPIA for the service has been completed and signed off.

SEPA is the regulator for the Water Environment (Controlled Activities) (Scotland) Regulations Act. We have responsibility for the Private Sewage Treatment Systems (PSTS) registration service and work with customers to help them understand their obligations and what they need to do to comply with the regulations.

Currently our digital PSTS service only accepts applications for systems that are more than two years old. We are looking to expand this service to allow customers to register a new private sewage treatment systems or those that are less than two years old.

This EqHRIA covers ‘New PSTS’ registrations to SEPA only, a previous EQIA is in place for the existing PSTS service.

The digital ‘New PSTS’ service requires an individual to say where the private sewage treatment system will be located, so makes use of graphical map services. Details on how this issue is mitigated for protected classes and groups of people are included in the Q4 section of this document.

There are many ways of making an application to SEPA for a New PSTS, including:

• Online form, payment and confirmation.
• Electronic documents – PDF, word documents.
• Paper documents.

SEPA’s Equality Outcomes 2022-2026

• Outcome 1 – We have increased the number of people from currently underrepresented groups in our applicants, our staff and those who progress within the organisation.
• Outcome 2 – People with lived experience of inequality, related to a protected characteristic or socioeconomic status, access and use SEPA’s services without barriers.
• Outcome 3 – Staff with lived experience of inequality and barriers, and with a wide variety of needs, feel listened to and respected as SEPA meets those needs.
• Outcome 4 – We have decreased our gender pay gap and occupational segregation related to gender, disability, and ethnicity.

This work will deliver on Outcome 2 by expanding access to SEPA’s online digital licensing services to under-represented groups and people with lived experience of protected status inequality by:

• Upgrading functionality for people who use screen-reading and/or screen-magnifying software;
• Using simple, plain English that can be understood by people with low literacy or for whom English is not a first language;
• Following Digital Scotland Service Standards during design of the service to give a simpler and consistent user experience;

The service went through accessibility testing on 16/05/2024 and the outcomes were used to change the service to improve accessibility in line with the user needs.

Yes. The service allows people with private sewage treatment systems that are less than 2 years old to apply online. It supports the change in policy to increase the number of properties that can apply from 3 to 10 (or from 15 population equivalent to 50 population equivalent).

The New PSTS service will impact:

• Direct applications to SEPA (a representative, or an individual will need to provide application information).
• SEPA Staff, who will be administering and providing the New PSTS service.

This extension to SEPA’s PSTS service will provide benefits to end users and SEPA staff by:

• Making the application simpler to register a new private sewage treatment system.
• Helping individuals to meet their obligations for their new private sewage treatment system.
• Providing a paper application and guidance for users who cannot, or chose not to, access the digital service.

Some groups may find accessing the digital service more challenging than others. This includes those who are deaf or hard of hearing, those who are blind or partially sighted, those who are neurodiverse and those with low digital skills. Accessibility testing was carried out on 16/05/2024 with participants from these groups and significant accessibility issues were resolved prior to the service going live.

Accessibility (Disability)

• 32% of adults had a long-term limiting mental or physical health condition of disability in 2017. Source: Scottish Government Scottish Health Survey 2021. (Disability; Population).
• Only 46% of disabled people of working age are in work. Source: Disabled people in the labour market in Scotland 2018. (Disability; Labour Market).
  • According to the last SEPA Mainstreaming and Outcomes Report 2023, 2.48% of staff declared a disability. Note: there may be under-reporting of this, so it may not be clear how many colleagues have disabilities or the forms of disabilities.
• 2% of the working age population becomes disabled every year, 78% of disabled people get their impairment aged 16 or older. Source: St. Andrews University Disability facts
  • As with the wider Scottish workforce and population, SEPA’s workforce is aging, with the largest age group (45-54) sitting at 39.2% of the workforce. With a higher number of older workers, the more pressing these concerns are.
• Significant sight loss affects around 188,000 people in Scotland. This figure is set to double by 2031 due to an aging population. Source: Sight Scotland. Using those figures as a basis, this now stands at 230.400 people in 2024.
• With regard to displaying map information, 4.5% of the population, are colour blind. Source: BBC.
• 10% of the population are believed to be dyslexic. Source: Dyslexia Scotland
• It is estimated that 1 in 7 people (more than 15% in the UK) are neurodivergent. Source: ACAS (national archive).

Accessibility (Literacy)

• 6.2% of Scotland’s population cannot speak, read and write English. 1.4% of the population cannot speak English well or very well. Source: 2011 National Census
• 26.7% of Scotland’s population have occasional challenges due to their lack of literacy skills. Of this percentage, 3.6% face serious challenges in their day-to day lives. Source: Scottish Survey of Adult Literacies 2009

Table 1 - Public Sector Equality Duty - Screening tool

Will the policy or practice engage or restrict a right or freedom under the Convention?

Look at each Article in turn and record your answer in Table 2.

If you answer ‘Yes’ for any of them, go to Section 3.

This guidance outlines where your work may impact on human rights - Human Rights human lives a guide for public authorities

Table 2 - Human Rights consideration

If you answer ‘Negative’ in Table 1 or ‘Yes’ in Table 2 for any of the questions, please go to Section 3 Full Assessment.

If you answer 'Positive' or ‘Neutral’ in Table 1 or ‘No’ in Table 2 for all of the questions you may not need to carry out a full assessment. You should discuss this decision with the senior leader responsible for the work.

If you are content you have completed Section 2 with no negative equality or human rights impacts, please complete Section 5.

• Eliminate unlawful conduct
• Advance equality of opportunity
• Foster good relations

Of the protected characteristic groups specified in Table 2, the PSTS service has the potential to impact only 1: Disability.

Some groups may find it harder to use the digital service including those who are deaf or hard of hearing, those who are blind or partially sighted, those who are neurodiverse and those with low digital skills. This may result in a negative impact on SEPA’s ability to comply with the ‘Eliminate unlawful conduct’ element of the Disability protected characteristic group.

Disability, including those who are deaf or hard of hearing, those who are blind or partially sighted, those who are neurodiverse and those with low digital skills.

The groups who may find accessing this service more challenging than others were those who are deaf or hard of hearing, those who are blind or partially sighted, those who are neurodiverse and those with low digital skills.

Accessibility testing was carried out on 16/05/2024 with participants from these groups. This highlighted some accessibility issues that were resolved prior to the service going live.

This new service will provide some positive impacts e.g. enabling applicants who are blind to apply online using a screen reader.

The service also reduces the time it takes to apply and receive a SEPA authorisation from the statutory period of 28 days to about 20 minutes.

For people who do not wish to use the online service new, simpler and accessible application documents are available. The guidance is also accessible.

The New PSTS service may negatively impact people who have a disability including those who are deaf or hard of hearing, those who are blind or partially sighted, those who are neurodiverse and those with low digital skills. These groups of people may find it harder to use aspects of the digital service.

To mitigate any negative impacts the online NEW PSTS service has been developed in line with the Scottish Government’s digital strategy and Digital First assessment standards.

• Online forms are simpler with one question per page and only ask for information required by SEPA.
• Questions are written in plain English to be as clear and simple as possible.
• Display fonts, colours and sizes of text and controls are clear and consistent with the Scottish Government’s design system.
• On-line forms have been accessibility tested with users that have visual, hearing, physical and cognitive disabilities. Key findings and recommendations have been addressed.
• Where there are known accessibility issues (the map services), information can be entered in another way. This allows individuals with visual or dexterity conditions to bypass those elements of the service.
• Accessibility testing was carried out on 16/05/2024 with participants who have accessibility needs. The feedback was used to improve the service before going into production.

Guidance is in place for the digital service, electronic and off-line paper form applications.

The details for Contact Scotland BSL (British Sign Language) are on the SEPA website, for users who wish to access an interpretation service. They are also available from SCC and Registry Staff.

Digital and telephone services (via SEPA’s Contact Centre) are available for people who need to ask, complain or report a matter in connection with the CAR Regulations.

There is guidance for staff and applicants to help them understand PSTS obligations. This is available in digital and paper-based formats and can be supplemented by telephone or video call.

SEPA’s website provides guidance and services, partner organisations and ways to progress queries that do not fall under SEPA’s remit.

The NEW PSTS service includes an opportunity for users to provide feedback to help improve the service going forward.

General feedback received from Accessibility Testing was positive and highlighted the easy-to-use design and layout of the service pages. SEPA will regularly monitor service use and take action to address any issues.

SEPA staff that are supporting and administering the service will use MS teams to provide video conference call support.

The digital registration service uses Microsoft Dynamics as the back-office solution. Microsoft products are widely tested and work with a wide range of assistive technologies such as screen readers. Microsoft 365 cloud products have been designed with accessibility built-in to meet the differing needs of users.

Accessibility (Disability)

• 32% of adults had a long-term limiting mental or physical health condition of disability in 2017. Source: Scottish Government Scottish Health Survey 2021. (Disability; Population).
• Only 46% of disabled people of working age are in work. Source: Disabled people in the labour market in Scotland 2018. (Disability; Labour Market).
  
  • According to the last SEPA Mainstreaming and Outcomes Report 2023, 2.48% of staff declared a disability. Note: there may be under-reporting of this, so it may not be clear how many colleagues have disabilities or the forms of disabilities.
• 2% of the working age population becomes disabled every year, 78% of disabled people get their impairment aged 16 or older. Source: St. Andrews University Disability fact finder
  • As with the wider Scottish workforce and population, SEPA’s workforce is aging, with the largest age group (45-54) sitting at 39.2% of the workforce. With a higher number of older workers, the more pressing these concerns are.
• Significant sight loss affects around 188,000 people in Scotland. This figure is set to double by 2031 due to an aging population. Source: Sight Scotland. Using those figures as a basis, this now stands at 230.400 people in 2024.
• With regard to displaying map information, 4.5% of the population, are colour blind. Source: BBC.
• 10% of the population are believed to be dyslexic. Source: Dyslexia Scotland
• It is estimated that 1 in 7 people (more than 15% in the UK) are neurodivergent. Source: ACAS (national archive) Neurodiversity in the workplace

Accessibility (Literacy)

• 6.2% of Scotland’s population cannot speak, read and write English. 1.4% of the population cannot speak English well or very well. Source: 2011 National Census
• 26.7% of Scotland’s population have occasional challenges due to their lack of literacy skills. Of this percentage, 3.6% face serious challenges in their day-to day lives. Source: Scottish Survey of Adult Literacies 2009

The service underwent accessibility testing on 16/05/2024 with results provided in an Accessibility Test Report.

Option 2: Adjust the policy / practice

This involves taking steps to:

• remove any barriers, to better advance equality or to foster good relations; and
• to minimise any restriction of Convention rights or freedoms.

It may be possible to remove or change the aspect of the policy that creates any negative or unwanted impact. You should describe additional measures which could be taken to reduce or mitigate any potential negative impact.

The service underwent accessibility testing in May 2024. The Accessibility report identified a number of areas for improvement and changes were implemented prior to the service going live.

The service includes a form for users to provide feedback upon completion of the application. This will be closely monitored, and issues addressed as they arise. This EqHRIA will be reviewed 6 months after service go live and updated to reflect any changes made to the service to improve accessibility following feedback.

The EqHRIA is a living document and should be reviewed and updated to ensure you have captured the changes that have been made because of the implementation of your policy or practice. Set a realistic goal for you to check back in with your assessment, to see if things are going the way you expected.

(16/01/2025)

11/07/2024

Yes.

Reviewed and signed off by Head of Permitting 15/07/2024