Consumer Scotland: draft workplan 2022 to 2023 – SCVO response to the Scottish Government

About us

The Scottish Council for Voluntary Organisations (SCVO) is the national membership organisation for the voluntary sector. We champion the sector, provide services, and debate big issues. Along with our community of 2,900+ members, we believe that charities, social enterprises, and voluntary groups make Scotland a better place.

About the Scottish voluntary sector

Scotland’s voluntary organisations are focused on delivering vital services and empowering some of Scotland’s most marginalised communities. The sector has a role in all aspects of Scottish society, from tourism and housing to the justice and social care systems.

The sector is an essential part of Scotland’s economy, encompassing an estimated 40,000+ organisations, from grassroots community groups and village hall committees to over 6,000 social enterprises, and approximately 25,000 registered national charities.

About our submission

The Scottish Council for Voluntary Organisations (SCVO) welcomes the opportunity to respond to the Scottish Government’s consultation on Consumer Scotland’s draft workplan for 2022 to 2023. Our submission is short but provides what we believe is an important perspective from the voluntary sector on the scope of Consumer Scotland’s work.

Our response

As the national membership organisation for the voluntary sector, it is part of SCVO’s role to identify areas of work or legislation in which the sector, or parts of the sector, may be impacted, be it positively or negatively. Often, the voluntary sector can go unnoticed or forgotten about when it comes to the messaging employed around particular areas of work, calls for views, or consultations which are not explicitly related to the sector but do still involve an impact. In these cases, it can require further investigation by ourselves or others, often with clarification sought from the Scottish Government and other bodies, to identify where the views of the sector need to be heard but where the messaging around this has not been clear. SCVO would like to thank Consumer Scotland for providing us with further information that we have used to inform our response. 

Not-for-profit enterprises as consumers

The Consumer Scotland Act 2020, which establishes Consumer Scotland and provides for its functions as a consumer advocacy and advice body, defines a consumer as “an individual, or a business no larger than a small business, that purchases, uses or receives goods or services in Scotland, where those goods or services are supplied in the course of a business”. It is our understanding that the term “small business” relates to organisations with less than 50 employees.

In section 25 of the Act (Interpretation), confirmation is provided that “a business is defined widely to include a not-for-profit enterprise which exists wholly or mainly to benefit society or a profession as well as the activities of any government department, local or public authority or other public body”. Therefore, the Consumer Scotland Act 2020 confirms that the scope of Consumer Scotland’s remit will include not-for-profit enterprises of up to 50 employees.

In Scotland, we enjoy the benefits of over 40,000 voluntary organisations, including more than 6,000 social enterprises, 25,000 registered charities, and over 100 credit unions. Together, these organisations employ over 100,000 paid staff – the same as the digital and technology sector in Scotland. However, we know that the majority of organisations within the voluntary sector, who would presumably meet Consumer Scotland’s definition of a consumer, do not employ more than 50 employees. Therefore, we feel it is important to stress that a sizeable part of Scotland’s voluntary sector should be more visibly considered within the scope of Consumer Scotland.

It is not only important to recognise that this is the case, but also to highlight that the messaging employed with regards to Consumer Scotland to date may need to be developed further to ensure that not-for-profit enterprises are fully aware of their right to the body’s advocacy and advice services, and to understand the potentially beneficial contribution they can make in consultations such as this.

Consumer issues across sectors - additional focus

With the above in mind, we suggest that consideration is given to an additional focus within Consumer Scotland’s workplan to improve outcomes for consumers in Scotland. As energy costs continue to rise in the shadow of a global pandemic which has already exacerbated financial issues faced by Scotland’s voluntary sector, it is vital that the ability to access essential services such as energy and water is not impeded. Despite playing a crucial role, over the past two years in particular, many local and national voluntary organisations are facing a difficult struggle to continue providing vital services to Scotland’s communities in the face of barriers preventing core and longer-term funding. Wave two of SCVO’s Scottish Third Sector Tracker has shown that, over the winter, 52% of voluntary organisations were facing financial challenges, up from 47% in the Tracker’s first wave over the summer. Current escalating energy costs will only compound those challenges.

SCVO would like to propose the addition of a focus within the “consumer issues across sectors” section of the workplan on understanding the difficulties and pressures facing consumers in the voluntary sector. This focus would acknowledge the increased pressures placed on not-for-profit enterprises in Scotland resulting from spiralling energy costs at a time when the future of funding for organisations, services, and projects is uncertain. This focus would acknowledge the phenomenal role of the voluntary sector in Scottish life, working to better understand the real impact of price increases on consumers from within the sector and investigating alternative approaches to the targeting of support. This would help to ensure that we do not lose vital local and national voluntary organisations and services as a result of escalating energy costs.

With the Scottish Government and Consumer Scotland’s commitment to the Net Zero agenda, such a focus would also allow Consumer Scotland to further its work in this particular area. As stated previously, there is the significant section of the voluntary sector in Scotland that should be considered as consumers by Consumer Scotland’s definition and, therefore, it is vital that the size and scale of the sector is considered in Scotland’s efforts to decarbonise and reach Net Zero. Organisations from within the voluntary sector want to play their part in those efforts and including a focus within the workplan specifically on not-for-profit enterprises in Scotland would allow Consumer Scotland to better understand the support that voluntary organisations, charities, and social enterprises may require in order to play what is a crucial role in achieving a Net Zero Scotland.

We also believe that part of Consumer Scotland’s work programme going forward should be focused on how the body communicates its role effectively, particularly with regards to small organisations, including those within the voluntary sector, to ensure that all consumers are informed of the body’s work and services. Essentially, consumers entitled to potentially vital advice and advocacy services should be fully informed of this without the need to understand legislative definitions and interpretations.

Conclusion

Scotland’s voluntary sector is an integral part of the Scottish economy, and delivers enormous social benefit, often working with the most marginalised communities. The work of the sector touches on all parts of Scottish society, from tourism and housing to the justice and social care systems. It is vital that a body such as Consumer Scotland recognises this contribution and acknowledges the difficulties currently facing not-for-profit enterprises, which will only be worsened by increasing energy costs. With an annual turnover eclipsing £6bn, and over 100,000 paid staff connecting with more than 1.2m volunteers, the Scottish voluntary sector is an invaluable part of Scotland’s society and economy, with tens of thousands of consumers found within it, and this should be recognised within Consumer Scotland’s workplan for the forthcoming year.

Contact

Jason Henderson, Policy and Public Affairs Officer
Scottish Council for Voluntary Organisations
jason.henderson@scvo.scot