FSS post-UKSC equality compliance, safeguarding, immigration-linked food risks, ideological neutrality & public funds

Date published:

Request

Your request was about the following information:

Regime: Where any part of this request is for information which you consider to fall under the Environmental Information (Scotland) Regulations 2004 (EIRs), please treat that element as an EIR request and respond accordingly. Where it falls under 

the Freedom of Information (Scotland) Act 2002 (FOISA), please treat it as such.

Under FOISA/EIRs, please provide the information below. Where possible, supply data in CSV/Excel and documents as searchable PDFs. If material is already published, please provide the specific URLs

Q1. Post-UKSC legal position & internal actions

Q1a. Any internal/external briefings, legal analyses or summaries produced or received since 16 April 2025 regarding the UK Supreme Court ruling clarifying that the protected characteristic of “sex” in the Equality Act 2010 refers to biological sex, and its implications (if any) for FSS policy, guidance, enforcement or communications.

Q1b. Any Equality Impact Assessments (or equivalent) created/updated since 1 Jan 2024 that touch on equality terminology, sex/gender references, or belief protections in relation to: official guidance, enforcement frameworks, communications, or staff policies.

Q2. Guidance/communications to enforcement bodies & industry

Q2a. Copies of FSS guidance, circulars, supervisory letters or speeches since 1 Jan 2019 issued to local authority enforcement teams, Port Health Authorities, or food business operators that cover any of:

• legally accurate Equality Act terminology in policies/customer interactions; 

• protections for freedom of belief (including gender-critical beliefs) and avoidance 

of compelled speech/ideological endorsement in workplace/customer-facing settings; 

• avoiding misleading EDI claims in public communications or reports.

Q2b. A list (title + date) of any unpublished guidance/FAQs touching the above topics.

Q3. Inspections, incidents & enforcement (1 Jan 2019 – present)

Q3a. Counts of inspections, incidents, investigations, compliance interventions or enforcement cases in which one or more issues included:

(i) Equality Act 2010 terminology/compliance;

(ii) compelled belief/ideological neutrality;

(iii) safeguarding or protection of vulnerable persons (e.g., whistleblowers, trainees, young workers).

Q3b. For each such item, an anonymised table with case ID/reference, date opened, nature of issue, and outcome (e.g., no further action, guidance issued, formal notice, prosecution, etc.).

Q4. Immigration/resource-linked safeguarding in the food system

Q4a. Any MoUs, protocols or liaison notes (1 Jan 2019 – present) between FSS and the Home Office, Border Force, Police Scotland, GLAA, local authorities or the UK Health Security Agency that address immigration-linked risks relevant to food safety/food crime (e.g., illegal imports, food fraud, trafficking/forced labour indicators encountered during inspections), including referral pathways and safeguarding arrangements.

Q4b. Any risk assessments, thematic analyses or board/committee papers (1 Jan 2022 – present) concerning immigration/resource-linked vulnerabilities within the Scottish food supply chain, including ports and postal/import channels, and any actions arising.

Q5. Public funds & procurement (EDI/DEI)

Q5a. FSS spend since 1 Jan 2019 on external EDI/DEI advisory, memberships, benchmarking or training providers (supplier, description, amount, start/end dates).

Q5b. Any procurement templates/scoring criteria used since 1 Jan 2019 that include EDI/DEI conditionality or mandatory policy commitments for suppliers.

Q6. Internal policies & training (post-UKSC and current)

Q6a. Current versions and any versions updated since 16 Apr 2025 of policies on: Equality, Dignity/Respect at Work, Freedom of Expression/Belief, Whistleblowing, Safeguarding of complainants/whistleblowers, and Impartiality/ideological neutrality.

Q6b. Training materials (slides/handbooks/outlines) used for staff/managers on these topics.

Q7. Governance & oversight

Q7a. Board or committee minutes/packs since 1 Jan 2024 where any of the following were discussed: the UKSC ruling; equality terminology; safeguarding; immigration[1]linked risks to food safety/food crime; EDI procurement/spend. Please provide titles, dates, and redaction grounds where applied.

Q7b. Any forward workplans indicating planned changes to guidance, enforcement approach or communications touching these topics.

Q8. Data protection & retention

Q8a. Any DPIAs, LIAs, ROPAs, retention schedules or policy notes (since 1 Jan 2023) governing collection/processing of equality-related data or safeguarding/complaint data in enforcement/HR contexts.

Q9. Disclosure log

Q9a. Links or copies of prior FOI/EIR responses (2019–present) concerning Equality Act compliance/terminology, safeguarding, ideological neutrality, immigration[1]linked food risks, or EDI/DEI procurement/spend.

Format & exemptions

If you consider any FOISA exemptions or EIR exceptions apply, please: (i) identify each per item; (ii) provide the public-interest test where relevant; and (iii) release all non-exempt material in partial/redacted form. If the same document is responsive to multiple parts of this request, please indicate all relevant parts rather than duplicating or withholding it.

Duty to advise and assist

In accordance with FOISA s.15 and EIR Reg. 9, please provide advice/assistance if scope refinement would enable full compliance. If any item risks exceeding cost limits, please process the remainder and propose a narrowed form (e.g., lists/indexes, shorter date range) that would fall within the limit.

 

Response

A1a. An interim update was provided to staff on the 15th May via our CEO Weekly Newsletter as below: 

Supreme Court ruling on the Equality Act 2010 – interim update 

The Scottish Government (SG) has noted the interim update from the Equality and Human Rights Commission (EHRC) following the Supreme Court’s ruling on the definition of a woman in the Equality Act 2010.  

 The EHRC plans to launch a stakeholder consultation in May, and to provide an updated code of practice to the UK Government for Ministerial approval by the end of June. 

All colleagues are reminded that individuals may be impacted by this ruling in different ways and should be reassured we are committed to promoting equality and diversity in the SG. Colleagues are reminded of the support available to them through our ‘Wellbeing and Staff Support’ document. 

Any colleagues who have concerns about what the judgement means for them can email Rachael.Schofield@fss.scot in confidence. There has been no further communications or guidance published locally from FSS. Any further guidance will be provided and published by SG as and when further guidance is published by the EHRC.

A1b. We do not update staff policies locally, and no EIA’s have been created or updated since 1st January 2024 that refer to equality termination, sex/gender references or belief protections. We are unable to comment on enforcement frameworks or communications.

A2. Food Standards Scotland (FSS) does not hold this information.

A3. Food Standards Scotland (FSS) does not hold this information.

A4. Food Standards Scotland (FSS) does not hold this information.

A5. Food Standards Scotland (FSS) does not hold this information.

A6. Internal policies & training (post-UKSC and current) 

- Please see annex A attached for the Stamp It Out Campaign presentation. 

- Please see annex B attached for the Whistleblowing presentation.

The annexes contain the FSS internal training materials referenced.

Copies of SG/Civil Service-Learning training materials are not included as they are not owned by FSS.

A7a. Food Standards Scotland (FSS) does not hold this information.

A7b. Food Standards Scotland (FSS) does not hold this information.

A8a. DPIA for Oracle Cloud HR and Finance System this includes data collection including equality related data which covers the HR context. 

DPIA - HCM FINAL VERSION 2024 08 22

Did you find this helpful? We would love to hear from you.
Thank you for your feedback!