Consultation Response Form

Your name:         Alison Scouller

Organisation (if applicable): Socialist Health Association Cymru

Consultation questions

The Action Plan has three distinct areas we would like you to give us your thoughts on. They include the vision setting pages, the policy themes with their goals and actions and the governance section: 

1.   Does the vision, purpose, values and the imagined future to 2030 reflect what you would like to see achieved by 2030? What may get in the way to realise the vision and values? What may help to realise the vision and values?

As Socialist Health Association Cymru (SHAC) we set up a working group to look at the issue of inequalities in health with particular regard to the Black, Asian and Minority Ethnic communities in Wales. We invited non-members from the Black, Asian and Minority Ethnic communities to our working group to assist us as we recognised the importance of these issues in terms of addressing inequalities in health and social care. Also, within our organisation we needed to become more representative of the Black, Asian and Minority Ethnic communities in Wales. We have put quotes from the Plan in italics.

The SHAC liked the statement on p 5 that ‘the Plan is built on the values of anti-racism’, acknowledging that most people in society are generally non-racist, but that is not an action-oriented state with a conscious awareness. Therefore, negative racial stereotypes of ethnic minority groups can influence people to be unconsciously racist.  This is enhanced by the statement on page 25 that ‘Anti‑racism appears to be a preferred term to race equality, as it signals conscious awareness and a positive readdressing of institutional racism by leaders at all levels;’ 

SHAC, as an organisation not currently reflecting the ethnic diversity of Wales, is supportive of the hope ‘that white people will “engage in challenging (their white privilege) and enriching themselves (by being curious about cultures and traditions different to their own)” so “we are at ease with each other”. We will have talked “about the elephant in the room”, “about white superiority and entitlement to set the rules”. We “want to embrace and be comfortable about what unites us, rather than what divides us” (page 25).

SHAC’s membership consists of people committed to ending inequalities in health, many of whom have been active in health and social care for over 40 years. It is sad to reflect that we still need to have this debate and therefore the statement on page 27 ’By 2030 the Welsh Government will have:  Made “no more promises but have delivered, delivered, delivered!”’ rings true.  However, as is emphasized elsewhere in the Plan, the creating of an anti-racist Wales is down to everyone in society not just Welsh Government.  We welcome the proposed monitoring of the plan.

2.    We would like your views on the goals and actions. To comment on some or all of the goals, actions and outcomes please reflect on the below:

(a) Does the explanation (narrative / background) make clear why we have chosen the goals and actions in this policy area?

(b) Is it missing any priorities, background or other information?

(c) Do you agree with the selected goals and actions? What would you add or take away in relation the actions?

(d) Will each goal and associated actions create the desired outcomes we have stated? If not, what would you want to change so that we achieve changes that are truly anti-racist in the time scales stated?

(e) How could the positive or negative effect be increased, or mitigated?

• Education:

• Hateful crime and justice:

• Housing and accommodation:

• Employment and income:

• Health:

• Social Care:

• Leadership and representation:

• Arts, Culture, Sports and Heritage:

• Environment:

• Welsh Language:

•    Local democracy:

•    Cross-cutting issues:

Because we are the Socialist Health Association, we have concentrated our comments on Health and Social care, relating our comments to the different goals. However, we recognise that many inequalities in health are caused by factors such as housing, environment, employment, income and issues with education, lack of access to sports and cultural facilities/activities, and the problems with the justice system. Therefore, we are pleased that the Plan is so comprehensive.  On leadership and representation, apart from the leadership of public bodies, the candidates selected to fight council, Senedd and Parliamentary seats do not to reflect the racial diversity of Wales. It is vital that this is addressed perhaps by legal and procedural means, to widen the range of candidates selected to fight seats. 

Health Services and Health Outcomes

Goal 1 To ensure that NHS Wales is anti-racist, with zero tolerance of any form of discrimination or inequality for employees or service users.

With regards to health services, attitudes to people of different cultural backgrounds can affect their engagement with health services. It is important that key cultural norms are explained to health care providers and adequate training provided to enable people of all cultures to feel well received when they attend health facilities for care, e.g. referring to people from certain backgrounds in culturally appropriate ways for their age. 

In relation to mental health, particularly since the start of the COVID 19 pandemic, Welsh society has become increasingly aware of the need to address this properly.  The importance of understanding how cultural backgrounds affect perceptions and individual experiences of mental health and how health and social care providers, professionals and carers need to appreciate this, has long been recognised if not adequately acted upon.  Perhaps though the direct impact of racism on mental health has not been acknowledged.  This impact is highlighted on page P 27: ‘We believe that by 2030 we should all be seen as “Welsh”, with “the problem of racism, which leaves trauma that “affects mental health for years no longer upon on our shoulders”.’  This affects children’s mental health in particular ways and puts emotional and psychological strain on their parents and the other significant adults in their lives. SHAC believes that health and social care providers, professionals and carers must gain understanding of this.    

These considerations also apply to Goals 1, 2 and 3A about Social Care (To ensure that all Black, Asian and Minority Ethnic people feel confident in accessing and using social services and social care services whenever they are needed AND To ensure that all Black, Asian and Minority Ethnic people who access social care services are provided with the highest quality support that is accessible, dignified and culturally appropriate AND To ensure that all members of the social care workforce have the cultural competence to work effectively with people from diverse racial, ethnic and cultural backgrounds and ensure that this support is delivered with zero tolerance of racism and any other form of discrimination or inequality)

The impact of Adverse Childhood Experiences has been recognised and is now being acted upon by Welsh Government.  However, there is insufficient understanding as to how these are experienced by, and impact upon, children (and later adults) from Black, Asian and Minority Ethnic groups, and that therefore they need to be addressed in different ways. Furthermore, the COVID-19 lockdown has had a huge impact on young carers. Research needs to be carried out in this area to inform culturally appropriate services. 

Also, SHAC has heard from Black, Asian and Minority Ethnic women’s organisations that women can be

reluctant to leave abusive situations because of the racism they believe they will encounter from agencies

which should be there to support them with culturally competent and anti-racist practice.

Goal 2 To ensure that the NHS Wales workforce reflects the population it serves; and staff work in safe, inclusive environments (recognising specific challenges for women in the workplace) that enables them to reach their full potential recognising the intersectional factors causing cumulative disadvantage in an individual.

All NHS workers should receive training to make them knowledgeable of the cultural norms of all the cultures who work within the NHS. This should be bi-directional.

Goal 3 (Health Services and Health Outcomes) To ensure that health data in relation to race, ethnicity and intersectional disadvantage is actively collected, understood and used to drive and inform continued improvements in services and Goal 6 (under Social Care)– Data and Analysis To improve qualitative and quantitative data, research, evidence, analysis, intelligence and understanding to support and drive continued progress, including a significant increase in the lived experience data gathered from Black, Asian and Minority Ethnic people.

The need for better data has been demonstrated by the need to understand the greater impact of COVID-19 on Black, Asian and Minority Ethnic communities, and the realisation that there is lack of data in Wales. This was pointed out to SHAC by members of our working group. Our working group members told us that research grants are largely granted to white researchers to undertake studies on Black, Asian and Minority Ethnic people. They thought a better approach would be to support Black, Asian and Minority Ethnic organisations to conduct research, with support from academic organisations.

Furthermore, data gathering is flawed by the reduced numbers of minorities who contribute to surveys.  Therefore, it is important that, as part of data gathering exercises, a review is carried out of the reasons that there are low participation rates of Black, Asian and Minority Ethnic health care staff to surveys. 

Goal 4 To ensure public health messages to improve uptake and access to health services are developed through dialogue and in partnership; individuals are supported where necessary in order to access health care.

Black, Asian and Minority Ethnic women have been especially affected by COVID-19, directly (by the disease itself) and indirectly (in their mental health and economically).  We have heard from Black, Asian and Minority Ethnic women’s organisations that especially the older women they represent have suffered ‘digital exclusion’ but once enabled to use digital devices have gained much support in this way. The use of such virtual support during the pandemic has meant that local organisations have been able to reach across Wales, generating more ‘need’ for both facilities such as centres and more virtual groups.  Funding is needed to extend such support.  

Goal 5 To ensure disease and condition specific delivery plans and strategies include actions to address the evident health inequalities experienced by some Black, Asian and Minority Ethnic people.

The Plan notes inequalities within maternity care, so this clearly needs to be addressed.  Furthermore, feedback from women’s organisations is that there is a high proportion of older women who suffer with diabetes and hypertension.  They want to feel healthier and be part of the wider community in Wales. With regards to such chronic disease as diabetes and hypertension, significant inequalities exist in the outcomes and prognosis for many Black, Asian and Minority Ethnic people compared with white people. All Health Boards’ (HB) audit data for these conditions should include sections which compare the outcomes for these subgroups. Welsh government should mandate HB IMTs for chronic disease management to include set targets to improve outcomes for Black, Asian and Minority Ethnic people.  Overall HBs’ IMTs should include reference to the need to integrate the demands of the Plan.

Social Care: 

Goal 3B – Workforce. To ensure that Black, Asian and Minority Ethnic people experience no barriers in seeking a career or role within social care; that all Black, Asian and Minority Ethnic social care practitioners have access to the highest quality training throughout their career; and that all Black, Asian and Minority Ethnic social care practitioners are and feel safe within their workplace and have full confidence in the leadership of their organisation to operate a zero tolerance policy of anti-racism and any other form of discrimination or inequality.

SHAC believes that much more work needs to be done to address racism in the workplace.  Our working group reported such racism and that they knew people were afraid that complaining would threaten their own employment.  They felt that covert racism & institutional racism was not being dealt with properly by line managers.  It is suggested that a mentorship programme specific for the Black, Asian and Minority Ethnic workforce should be created which takes into account their cultural norms and differences and how they can be engaged to thrive in an antiracist workspace. Each HB should have such a scheme in place. Mentors should be adequately trained and resourced to make them sensitive and effective in supporting their mentees. 

Goal 4 – Leadership To ensure that leaders at all levels in social care model and champion anti-racism, diversity and inclusion and deliver an anti-racist social care sector for both people who are receiving care and support and for the social care workforce.

Goal 5 – Accountability To embed accountability actions and behaviours across the social care sector, including robust governance structures and clear, measurable metrics, in order to determine the impact and effectiveness of the social care sector in delivering the actions set out in this plan.

There is a need for sanctions to ensure compliance with the goals of the Plan.

3.       Are there any goals and actions that you can think of that are missing? Who should deliver on them and what actions would help to deliver them?

4.     What are the key challenges that could stop the goals and actions achieving anti-racism by 2025? 

A) Lack of funding, which may result from lack of sufficient funds coming to Wales from the UK Government via the ‘Barnett formula’.

B) All sectors not working to be actively anti-racist as opposed to non-racist.

5.     What resources (this could include funding, staff time, training, access to support or advocacy services among other things) do you think will be necessary in achieving the goals and actions outlined? 

In the past there have been many short-term funded projects and it would be better if there was more permanent funding available. Short term funding gives the impression of supporting a niche interest rather than a key issue. It is also not cost effective in the long run as it is less likely to address the problems.  Finally, time and money have to be wasted seeking the next source of funding. However, as noted in the previous question response, this may be out of Welsh Government control.  

6.     Do you feel the Race Equality Action Plan adequately covers the intersection of race with other protected characteristics, such as religion or belief, disability, age, sexual orientation, gender reassignment, sex, and marriage and civil partnership?  If not, how can we improve this?

SHAC believes that the paragraph on P 12 sums up so called ‘conflicting interests’ well. 

‘….. discussed the ways in which the Plan may alienate some members of the dominant community who may argue that very real problems faced by other people, for example white people from lower socio-economic groups, are not addressed by the plan. We recognise that many people face challenges and disadvantages and that COVID-19 is making this worse. There is a separate area of work, including the enactment of the socio-economic duty, being undertaken to address these issues. It is important, though, that we challenge this divisive analysis, and do not see a competition between the desirability of support for white people who are disadvantaged and the promotion of fair and equitable policies for Black, Asian and Minority Ethnic communities. Both are necessary and both can, and should, be achieved. …….Any progress on race discrimination is likely to result in fairer treatment for all disadvantaged groups by making systems fairer and more transparent and services more responsive and person-focused. In short, the Welsh Government wants to make Wales a more equitable, anti-racist country.’

SHAC liked the emphasis on intersectionality.  The statement on page 16 that ‘ethnic minority women’s voices and needs go unmet though policies and processes. This often results in ethnic minority women “falling through the gap” and their significant contributions to society being unrecognised and insufficiently valued.’ resonates. We hear from Black, Asian and Minority Ethnic women’s organisations that they had to work hard to ensure more coverage of the situation and needs of Black, Asian and Minority Ethnic women.  This has added to the pressure and workload of women leaders in these communities.  If intersectionality was better appreciated, then this would not have been necessary.

7.      Please see the section on Governance. What suggestions can you provide for measuring success in creating an anti-racist Wales and for strengthening the accountability for implementation?

8.     We would like to know your views on the effects that the draft regulations or the proposal in respect of the revised trading order would have on the Welsh language, specifically on opportunities for people to use Welsh and on treating the Welsh language no less favourably than English.  

 What effects do you think there would be?  How could positive effects be increased, or negative effects be mitigated?

SHAC think it is important to recognize that access to the learning and speaking of the Welsh Language

and Welsh language cultural activities and events is just as important to Black, Asian and Minority Ethnic

people as to anyone else in Wales.

• Please also explain how you believe the proposed draft regulations or the proposal in respect of the revised trading order could be formulated or changed so as to have positive effects or increased positive effects on opportunities for people to use the Welsh language and on treating the Welsh language no less favourably than the English language, and no adverse effects on opportunities for people to use the Welsh language and on treating the Welsh language no less favourably than the English language. 

This question is hard to understand but we think it is asking What else could we do to make sure the Welsh language is valued as much as English?

1. This plan has been developed in co-construction, and discussions around language and identity have shown that many people do not consider the term ‘BAME’ to be appropriate.  As a result we refer to Black, Asian and Minority Ethnic people or particular ethnic minority people in the Plan.  However, we recognise that this term is also problematic and, where possible, being more specific to the particular race or ethnicity an individual or community identifies with is generally preferred.  However, there are times where it is necessary to make reference to all those people who share the experience of being subject to racism.  We have used the term Black, Asian and Minority Ethnic people for this purpose.  What are your views on this term and is there an alternative you would prefer? Welsh speakers may wish to consider suitable terminology in both languages.  

None of the Black, Asian and Minority Ethnic in our group had an issue with this particular terminology. One commented that it is the purpose or intention that is problematic. There are distinct variations of the impact of the highlighted racial inequalities and constraints on different ethnic groups. It is important that these distinct differences are noted and prioritised for action. For example, the challenges faced by African health care professionals in the NHS are very different from those of south Asian health care professionals.

1. We have asked a number of specific questions. If you have any related issues which we have not specifically addressed, please use this space to report them:

The Plan acknowledges the disproportionate impact of COVID-19 on Black, Asian and Minority Ethnic communities in terms of the disease itself. In our working group members highlightedanti-South Asian racism manifested in different types of abuse.  This was supposedly due to COVID-19 ‘originating in China’. There has been some news coverage of this recently, but the abuse suffered by South Asian people has been going on since the start of the pandemic.  This has meant these communities have not only suffered from the effects of COVID-19 itself but have also been victimised by being blamed for the disease.  SHAC believes there needs to be recognition of and action on this type of racism.