Safety Cover

To provide a Safety Cover service for SEPA staff.

SEPA require a Safety Cover service that is fit for purpose in the wide range of environments and scenarios that staff work in and will utilise digital solutions to provide staff with a wide range of capabilities including proactively raising alarms or requests for help or assistance.

The organisation has chosen to use a digital approach to providing this service to staff to enable a higher degree of coverage than previous services and to ensure that a resilient system is in place for staff and managers in the event of an escalation. 

15/5/2024

Lauren Davidson

Kirsty Louise Campbell

A DPIA is also being completed to support the implementation of this service.

It was assessed that a full ICIA was not required, but a high-level assessment has been completed. 

The aim of this service is to provide a more resilient Safety Cover service for staff with more options for proactively raising alerts or requesting help as needed.

Through offering a wider range of personal safety devices, staff will be able to access the service in the way that best meets their needs e.g. via text, via voice note, in remote locations. 

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 service links with Outcome 3. We have engaged and consulted with a wide range of SEPA staff who use Safety Cover in their day to day role and have worked with UNISON and the Digital Lived Experience group to ensure this service can be implemented effectively for all staff (including appropriate support and training for all users).  The Digital Accessibility Lived Experience Group supports the aim of SEPA being an organisation that provides digital services and products that are accessible to all, specifically in this case helping develop policies, services and procedures, providing experience and expertise to make sure that digital accessibility is considered.

This service will replace the current Safety Cover service facilitated internally. 

Users- day to day users of the Safety Cover service. SEPA requires that when staff are lone working, i.e. working on your own, including in an office they make use of Safety Cover. It is also required when you remote working, whether alone or in groups of two or three, e.g. carrying out fieldwork in remote areas, working in areas where access to emergency services is limited, during out of hours travel or when travelling on remote roads or in bad weather, and when visiting problematic sites.

As part of a trial to test using an external provider and digital equipment, a group of 30 staff from across the organisation were asked to test devices and provide feedback on this new service. 
Briefings and training were provided prior to the trial commencing and weekly drop-in sessions were scheduled to allow for live feedback from users.

Line managers- previously line managers were required to be available until all their staff had closed off their Safety Cover and tracking who had taken out Safety Cover was difficult. With the new approach, line managers will not be individually responsible for monitoring their staff on Safety Cover or for dealing with escalations as a first contact. It is expected that removing this burden from line managers will free up time for them and reduce the amount of unpaid ‘good will’ overtime that resulted from dealing with escalations or ensuring their staff were home safely in the evenings.

Escalation managers- this new role was tested as part of the Safety Cover trial. A group of Band A and B managers used a duty rota approach to handle escalations. Managers were briefed before the trial started, trained on how to use the online manager portal for resolving escalations and asked for their feedback after their week of cover was complete.

UNISON- UNISON representatives were included in the trial and tested out the phone app and devices available. Some concerns around personal information were raised with UNISON and these were noted. As part of the trial, all users were provided with a demonstration of how a manager would access the manager portal and the type of information that would be available to view. It was also made clear that the portal would be accessed only in specific escalation scenarios, and not for any other type of monitoring.

Senior Leadership Team- SLT were engaged with early in the process as part of the overall project Oversight Board. Approval for the trial was agreed here, with an ask to present a review and recommendations for the Safety Cover service once the trial was complete.

SEPA Contact Centre- current facilitators of the service. SCC will be impacted as they currently provide this service for staff but will no longer. SCC staff have attended information sessions about the exploration of a digital Safety Cover solution and were also provided with a dedicated information session on the trial prior to it beginning. The SCC have also engaged with the wider Digital customer service project since October 2023.

Suppliers (Orbis and Vodafone)- the suppliers for this service have been engaged with from the planning stage of the trial. Vodafone are the current corporate telecommunication supplier.  

Internal stakeholder evidence gathering- a range of workshops were held with unit managers, line managers and Safety Cover users ahead of any trial development or planning around implementing a new system. Here experience and feedback from the current system was gathered, and requirements for the type of Safety Cover system that is needed were gathered.

Engagement with UNISON- UNISON were engaged early in the project, including 2 representatives taking part in the trial. Discussions around members concerns were undertaken, and the project team worked with UNISON, Health and Safety and with Information Governance colleagues to address these early concerns.

Digital Lived Experience Group – engagement in anticipation of roll out, to tie in with any training initiatives that are ongoing and ensure that consideration is given to the wide range of experiences with digital solutions that are within the organisation. 

Service and training will be rolled out to all staff, with support in using the technology provided where users may not be used to handling technology.

Within trial participants, there were a few who said they found it hard to get to grip with new technology and they had positive experiences, so the right support around this service offer is necessary. 

Different ways of communication that staff can choose from are available via this service. This includes voice calls, voice notes or text functions. They can proactively raise alerts to the highest level if needed as well as access the services provided by the lone worker support service.

 
Challenges posed to certain groups can be reduced or removed with the presence of the lone worker support service. 

Some people may find themselves in a vulnerable or unsafe environment as they do their job and access to appropriate help (from the emergency services) or support (for example talking on the phone with the user until they are in a safe place) will provide reassurance to staff.

Challenges posed to staff within certain groups can be reduced or removed with the presence of the lone worker support service and the knowledge that help or support is available immediately. 
 

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

Implementation of this service will have a positive impact in eliminating unlawful conduct and advancing equality of opportunity. Additional personal safety equipment for staff, including automatic audio recording when a red alert is raised will offer staff a wider range of personal protection than is currently offered.

Once implemented, the system will be available to all staff and they can use a wide range of functionality, including voice and test notes to communicate. This ensures users can use the most appropriate means of communication for themselves. 

This service will be available to all staff. Previously Safety Cover was mainly used by staff who were conducting field work or site visits, but the new service will be accessible to all staff and guidance will be updated to reflect that the service should be used in the event of lone working in any environment (including office or laboratory lone working). 

A cross portfolio group have been engaged with ahead of service implementation, and have used the new technology and process for a trial period of 5 weeks.

In addition to this, we have engaged with UNISON and the Digital Lived Experience group.

The new service will offer staff a wider range of personal safety options in terms of access – they can use a phone app or a roaming sim device. This means they can opt for a device that suits their needs e.g. the user requires to contact the service supplier via text format rather than voice format. This can be used as and when needed by the user, no additional support is needed to set up this option.

Providing this support across the organisation will help in addressing challenges posed to staff within certain groups. These can be reduced or removed with the presence of the lone worker support service and the knowledge that help or support is available immediately. 

Equality outcomes – potential negative impact on Age and disability  
Age - potential negative outcomes in eliminating discrimination and advancing equal opportunities:

Some staff may not be used to accessing phone apps/devices and so may not feel comfortable using the service without adequate training and support.

Disability – potential negative outcomes in eliminating discrimination and advancing equal opportunities:

 
Some staff may require different formats or support in accessing the service. Some staff may require accommodations in accessing the technology (app or device) to ensure that they can use the service. One of the key criteria for implementation of this style of service was the requirement to be used by all staff, so an accessibility statement from the provider was required. 

Human Rights Outcomes - Article 8: Right to respect for private and family could be considered to be impacted by the service:

The service uses GPS location signal in a phone app or on a roaming sim device. The frequency that this location is sent to the service supplier can be changed by the user, however if the frequency is set to not send the location often in the event of an escalation, it may be difficult to contact the user.

In addition, an out of hours contact number should be supplied by the user to the service supplier. This is in addition to their work mobile number which will be the first number tried in the event of a timed out amber timer, or red alert. 

Equality outcomes – potential negative impact on Age and disability:

  
Age

Service and training will be rolled out to all staff, with support in using the technology provided where users may not be used to handling technology.

Within trial participants, there were a few who said they found it hard to get to grips with new technology and they had positive experiences, so the right support around this service offer is necessary.

Disability

We have worked closely with Learning and Development colleagues, and consulted with users across the organisation to ensure the right resources and support are in place for service implementation.  
The service also has a range of accessibility features which was a requirement for implementation to ensure that all staff can use the service.

Human Rights Outcome : Article 8

It’s important to have clear guidelines around when the data outlined above should be accessed. Information regarding the user including their contact details and their location (via the device) should only be accessed via the manager portal in the event of an escalation.
This data will not be used for any purposes other than when responding to an escalation.

A small group of Band A and B managers make up the escalation duty rota and so access to this data is already restricted. They are instructed that they should not access the manager portal unless prompted by the service provider to resolve an escalation. 
One of the functions available within the app is called ‘home safe’. This allows the user to designate an area/location of their choice (recommended as either your home or somewhere you routinely visit at the end of the working day) where, when they enter this area, any active alerts will be cancelled and they can be considered safe. This function provides users with a buffer of 150m of the chosen location, so they do not need to specify their address. This function is also set by the user, so they can pick a suitable location individually. 
When logged out of the app no data will be gathered. User instruction will explain this and ensure staff know that once they are logged out of the app at the end of their working day, no further information will be gathered via the app.

A DPIA has also been completed to ensure that this service is in accordance with data protection legislation and the principles of UK GDPR.

The out of hours contact number does not need to be the users personal phone number, but they need to be available at this number in the event of an escalation.

SEPA recognises that colleagues need to ‘switch off’ (called the right to disconnect and outlined in this paper) and not feel like they need to be contactable or conducting work outside of their standard working hours. There should be clear boundaries between the spheres of work and leisure means workers are more likely to take calls, respond to emails and return to work throughout the evening, effectively spreading the working day over a longer period, but outside of the parameters of official overtime. Studies from before the pandemic demonstrate that ‘always on’ work culture is a major trigger and accelerator of ill health – both mentally & physically. Studies have shown that if workers have a chance to mentally ‘switch off’ from their work, they are generally more productive, engaged on the job and convivial with colleagues. This applies to line managers who have previously been an escalation manager for their team out with normal working hours (potentially staying ‘switched’ on’ in the evening waiting for all staff to be marked as at home and safe), as well as to staff who will be using this service and will have the ability to log out of the app completely or turn off their work phone when not at work. 

Internal stakeholder evidence gathering was carried out via a range of workshops held with unit managers, line managers and Safety Cover users ahead of any trial development or planning around implementing a new system. Here experience and feedback from the current system was gathered, and requirements for the type of Safety Cover system that is needed were gathered. A range of staff from different teams, different geographic locations and who do different types of work participated in these workshops.

UNISON was engaged early in the project, including 2 representatives taking part in the trial. Discussions around members concerns were undertaken and these concerns were addressed as the project progressed.

The Digital Lived Experience Group were engaged with in anticipation of roll out, to tie in with any training initiatives that are ongoing and ensure that consideration is given to the wide range of experiences with digital solutions that are within the organisation.

Internal policies were also reviewed to ensure that any service that was implemented would work in alignment with the organisation’s approach to keeping staff safe. This included the Violence and Aggression policy (and a Gender Based violence policy due for publication shortly). These policies promote safety among colleagues while at work and ensure that staff are equipped and supported to deal with any potential unsafe situations related to their role. 

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 main area that requires consideration and thought on reducing/mitigating potential negative impacts is the Right to respect for private and family life, specifically around GPS location when using the device. We have done this via:

• clear guidance for escalation managers (and information available to users) about when the manager portal (which holds GPS location data and a contact number for the user) will be accessed. This is for escalation resolution only and no other purpose.
• Completing a DPIA to ensure use of this service is in accordance with data protection legislation and the principles of UK GDPR.
• Eight Band A and B managers with access to the manager portal. The escalation manager group should not exceed this number and only these managers will have access to the manager portal in addition to the service manager.  
• Instructions to staff on how to:
  • Set their home safe zone. They do not need to enter their home address and can instead pick a general area.
  • Logging out. Once the user is logged out the app will no longer collect data.
  • Turn off devices. If using a roaming sim device, the device will no longer collect data when switched off.
  • Requiring an out of hours number for each user. This does not need to be their personal number but they need to be reachable via this number for escalation resolution. 

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.

01/03/2025

(19/08/2024)

Yes.