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Business regulatory impact assessment

An assessment of the census' impact on business.

Title of proposal

Scotland's Census 2022 programme

Purpose and intended effect


The census is the official count of every person and household in Scotland. It is usually held every 10 years and provides the most complete statistical picture of the nation available. It also provides information that central and local governments need, in order to develop policies and to plan, fund and run public services.

Scotland's Census is taken by the National Records of Scotland on behalf of the Registrar General for Scotland. The National Records of Scotland (NRS) is a non-ministerial department of the Scottish Administration, established on 1 April 2011, following the merger of the General Register Office for Scotland (GROS) and the National Archives of Scotland (NAS).

The main purpose of NRS is to collect, preserve and produce information about Scotland's people and history and make it available to inform current and future generations. NRS holds records of the census of the population of Scotland from 1841 and every 10 years after that. The one exception to date was the wartime year of 1941 when no census was taken. Census records are closed for 100 years under the Freedom of Information (Scotland) Act 2002.

Scotland’s Census moved to 2022

On 17 July 2020 the Scottish Government announced the decision to move Scotland’s Census to 2022 following the impact of the COVID-19 pandemic.

The census collection is a huge logistical operation involving the recruitment and deployment of thousands of staff, including a large field force team who engage with the public on their doorstep. The 12 months leading up to a census are vital in planning and testing the effectiveness and safety and security of census systems and collection processes to ensure these are ready. COVID-19 restrictions during 2020 prevented these key activities from progressing. These impacts occurred in a number of areas, from progressing recruitment to being able to undertake comprehensive testing, from contacting care homes and hospitals to establish their requirements for questionnaires to engaging with third sector and community groups to encourage participation from everyone in Scotland.

The priority and responsibility of NRS is to put in place a census that enables everyone across Scotland to participate, so that information collected can be used to produce high quality outputs and deliver the benefits required by the people of Scotland. NRS had been monitoring the impacts of COVID-19 on the delivery of the 2021 census and explored a number of options to preserve this census date. The conclusion by NRS was that the only option in which there was confidence around securing the high response rate required was to move the census to 2022. Following the recommendation, Scottish Ministers decided to move Scotland’s Census to March 2022 to ensure that a full and successful census is undertaken.

The census in March 2022 will follow the same model and question set as planned for March 2021. NRS will work closely with our stakeholders and partners to ensure that appropriate data is available to support work that was expecting to make use of Census 2021 data. NRS will also continue to work closely with our colleagues in the Office for National Statistics (ONS) and Northern Ireland Statistics and Research Agency (NISRA) to ensure the needs of data users in Scotland and across the rest of the UK will be met.

Why have a census?

For over 200 years, Scotland has relied on the census to underpin local and national decision making. Around 200 countries worldwide now undertake a regular census under the UN census programme. The census is the only survey to ask everyone in Scotland the same questions at the same time. It is unique in the provision of comprehensive population statistics. It is used by central and local governments, health boards, the education sector, the private sector, and the voluntary sector to plan and distribute resources that match people's needs. The information collected must be "authoritative, accurate and comparable" for all parts of Scotland, and down to very small levels of geography. Only the census can consistently provide such information.

Basic information on population size, age, sex and location are crucial to work on pensions, migration, economic growth and labour supply. Other information gathered helps governments to:

  • identify housing demand and create housing supply including information on household size and family make-up which are crucial to policies on local housing demand and planning, and poor housing and overcrowding
  • identify areas of deprivation, enabling them to target services
  • gather data on equality groups, enabling them to tackle discrimination
  • gather information on housing.

Census information is also used for a range of social and economic indicators:

  • population estimates
  • employment and unemployment rates
  • birth, death, mortality, and fertility rates
  • equalities data, such as age, sex, ethnicity, religion/belief and disability.

Census data is also used by local public services to meet local needs in health, education, transport, planning, and community care services.

Following the 2011 Census, NRS, in conjunction with the other UK Census offices, explored alternative ways to produce population statistics. NRS identified potential options and examined and compared various approaches to counting the population, both here and overseas, engaged with a diverse group of users, commentators and public bodies, and undertook qualitative and quantitative research into attitudes to the census and population statistics. More information on the work which was done can be found in the Beyond 2011 section of the NRS website.

Having considered all the evidence, in March 2014, NRS recommended that a modernised 'traditional' census was the best way to meet users' needs. Specifically, NRS announced its intention to focus on planning for a census which will be primarily online, while offering alternative modes of completion where necessary, and also aiming to make best use of technology and administrative data in its design, building on the online approach used successfully in the 2011 census.

The option of submitting census questionnaires online was introduced for the first time in 2011 to those living in households; those living in communal establishments were only able to complete on paper. Around 20% of all returns were submitted online. The 2022 Census is being designed under the principle of ‘Digital First’ with a target online completion ratio of at least 70%.


The main objectives of Scotland’s Census 2022 are to:

  • produce high-quality results;
  • generate outputs that meet the needs of our users;
  • maximise online response rates for the census;
  • produce timely outputs to maximise benefits;
  • protect, and be seen to protect, confidential information;
  • do so in a cost effective way; and
  • make recommendations for the approach to future censuses in Scotland.

Rationale for Government intervention

The Census Act 1920 ("the 1920 Act") provides for a census to be taken not less than five years after the previous census. The 1920 Act applies to England, Wales and Scotland. In Scotland it is the duty of the Registrar General to undertake the census, in accordance with the 1920 Act and any Order in Council or regulations made in terms of the 1920 Act, under the direction of Scottish Ministers.

The stated purpose of NRS is “to collect, preserve and produce information about Scotland’s people and history and make it available to inform present and future generations.” Conducting this, and future censuses, enables this purpose.

The provision of timely data outputs provides a necessary tool for the development of key business sectors in Scotland. This contributes to not only Scottish Government's Wealthier and Fairer strategic objective, but to longer term sustainable economic growth in Scotland.

Learning from Census Rehearsal

As part of our preparations for Scotland’s Census 2022, NRS undertook a public rehearsal in parts of Scotland. The rehearsal took place during October and November 2019. People living in households in parts of Glasgow City, and Dumfries and Galloway, and Na h-Eileanan Siar were asked to help by taking part, and received a letter in early October with more information about the rehearsal and how to participate.

Unlike the census itself, participation in the rehearsal was not a legal requirement. Householders in these areas were asked to take part on a purely voluntary basis to help ensure things go smoothly for the main census in 2022. Field force and communal establishment enumeration operations were not included in the rehearsal activities and the Contact Centre was operated internally within NRS.

The rehearsal also provided reassurance that our chosen approaches in many respects worked well. For example, initial contact materials and reminder letters were effective in encouraging returns, elements of our local engagement and marketing strategy tested strongly, and the overall design and functionality of the online and paper questionnaires allowed the public to complete returns and deliver usable data for our systems.

The rehearsal did importantly identify some new areas of improvement for NRS to take forward. These included the need to:

  • make improvements to how NRS collect address information;
  • make improvements to some online question routing;
  • review the timing and tailoring of reminder letters; and
  • improve the provision of management information.

The rehearsal evaluation report can be found on the Scotland’s Census website.

This BRIA covers the intended processes for communal establishment enumeration for the 2022 census and reflects the position post-rehearsal.


Within Government

The communal establishment enumeration process relies on a high-quality address register supplied by the NRS Geography Team. This register is quality assured through close regular collaboration with each of Scotland’s 32 local authorities, supported by the Improvement Service.

Public Consultation

No formal consultation is conducted on the topic of census enumeration. However, details on planning the 2022 census were updated in 2021 outlining census operations.

In preparing this Business Regulatory Impact Assessment NRS has gathered evidence from a wide range of sources and reflected on our own and others’ experience of previous censuses. In 2019 NRS held a series of stakeholder feedback sessions and conducted an online stakeholder survey to obtain feedback on the draft assessments. A report on the outcome of this period of consultation is published on the Scotland’s Census website.


How will the census impact businesses?

Scotland’s census responses are split into three main categories: standard households, communal establishments and population groups that require a dedicated approach.

The principle impact of the census on businesses will be the enumeration of communal establishments, and the legal responsibilities which fall to the managers of those establishments under census legislation.

A communal establishment is typically a managed residential accommodation where there is full-time, or part-time, supervision of the accommodation. Communal establishments include: hospitals, care homes, hotels, guest houses, B&Bs, youth hostels and halls of residence / student accommodation.

Enumeration is the process of collecting data from the people of Scotland during the census, including the operational aspects of census data collection. A robust enumeration strategy is essential to ensure a high level of participation during Scotland’s Census 2022.

Census enumeration activities are currently planned to commence three weeks before census day for households, and seven weeks before census day for communal establishments. Enumeration activity will continue beyond census day to encourage and enable a maximum response.

In preparation for the census collection in 2022, a pre-collect address check will be carried out for all identified communal establishments. This activity will request information from communal establishment managers on both the establishment and its residents in order to prepare census printed products for delivery.

A more indirect, but nonetheless hugely significant impact on business from the census is the value of the statistical data outputs it generates, which is put to numerous uses across the commercial sector amongst others. More information can be found at chapter 6 – ‘Benefits’.

Stakeholder Engagement during design

Engagement with organisations and managers within a variety of communal establishments was conducted during the early stages of the enumeration strategy development. Engagement with communal establishment managers will continue into 2022, to help:

  • promote the census;
  • explain the process of enumeration for their establishment;
  • help the manager understand their role in census; and
  • aid the preparation of census contact materials.

Following the move to a primarily online census for 2022, there have been changes to the enumeration strategy, including the communal establishment approach, in favour of a refined operational process.

The field force which supported Scotland’s Census 2011 was in the region of around 7,500 staff who were responsible for hand-delivery of paper census questionnaires to the vast majority of Scotland’s households. In 2022 initial contact with households will be by letter and field force responsibilities will focus on following up non-response. Field force will be around half the size of that in 2011.

Scotland’s Census 2022 will also see a divergence in the method of delivery to communal establishments, with contact materials being posted out by our supplier courier service, instead of hand delivered by enumerators. This will reduce the direct contact between the public and field staff. Collection of completed paper questionnaires will also be completed by our supplier courier service.

Communal establishment managers are required to issue, encourage completion of (online or paper) and collect completed paper questionnaires from residents. The Census (Scotland) Order 2020 provides that the communal establishment manager, or other person in charge.

With respect to any communal individual who is either; under 16 years of age, or incapable of making a return, the CE manager (or other person in charge), has a duty to make a return with respect to that person, or arrange for it to be made by a relative or other person accompanying that person.

Engagement pre-census

Engagement will continue as we approach census day and the enumeration team are conducting an enumeration address check against the communal establishment register (CER).

All communal establishments are contacted to:

  • introduce the census and the enumeration process;
  • make them aware of timescales (during the address check process NRS informed managers of when census day is and that they will be contacted again in early 2022);
  • confirm addresses and resident information in preparation for enumeration activity;
  • answer any questions they may have;
  • inform them of the census approach for their establishment; and
  • obtain manager’s contact information, name, telephone number and email address.

Communication methods for enumeration address checks

The following activity is ongoing:

  • Social media messaging, in line with the census integrated communications and engagement strategy, designed to raise awareness of the census ahead of our initial contact.
  • Introduction letter and establishment information request forms to communal establishment managers. This will include an introduction to the census, and an ask for mangers to complete the establishment information request to aid preparations.
  • Follow up contact to any non-responding establishment by telephone and email.
  • An e-mail address and phone number has been given on all communications to provide a line of contact for communal establishment managers to ask any questions they may have ahead of census collect.


Field-force option with no assistance from managers

Whilst ‘standard’ enumeration of Scotland’s households relies on detailed up-to-date address information and registers which NRS compiles and maintains, the numbers, locations and needs of residents of communal establishments does not show a complete picture of the requirements for each establishment within the address register. This therefore relies on the provision of supporting information and tasks by managers and other persons responsible for the establishments.

Without this supporting information, the management and effectiveness of the enumeration processes would be highly problematic with a high risk of undercount on a scale which could significantly impact the statistical viability of the census.

‘Do nothing’ option

To do nothing would constitute breach of the Registrar General’s duty to make arrangements and do all such things as are necessary for the taking of a census in terms of section 2(1) of the Census Act 1920.

Approved approach for Communal Establishment (CE) Enumeration

The communal establishment approach for 2022 has been reviewed and undergone revision to simplify the approach and processes. The overarching process for CE enumeration is:

  • Address check: All known establishments contained in the Communal Establishment Register (CER) have been contacted
  • Initial contact: Initial contact will be conducted by Census Area Managers to their assigned establishments to introduce themselves and census, confirm the details obtained at the address check and provide the courier delivery window of census materials to the establishment
  • Courier delivery: All establishments will receive their census initial contact packs by courier delivery within the delivery window
  • Support: Support to CE managers throughout collect phase (phone and email contact) will be provided by the Census Area Manager assigned to their establishment, they will provide their contact details to the CE manager at the initial contact stage. For CE 4 - Census Area Managers will attend the enumeration hub on the agreed day to support volunteers.
  • Follow up calls: Census Area Managers will conduct follow-up calls to all CE's. Where a response to the establishment questionnaire has not been received telephone data capture (TDC) will be carried out (excluding CE4 rough sleepers). They will also provide the CE Manager with the courier collection date/window (except CE 3)
  • Courier collection: Courier collection of completed paper questionnaires from the establishment (excluding CE 3 due to the online first approach for this group)

Further information on the different types of communal establishment is included below.

CE Type 1:

  • Care homes with nursing
  • Care homes without nursing
  • Staff/worker accommodation
  • Religious Establishments

CE Type 2:

  • General Hospital
  • Mental Health Hospital (including inpatient units)
  • Other Hospital
  • Other medical and care establishment
  • Prison and young offenders institution
  • Immigration Removal Centre
  • Children’s home
  • School
  • Other educational establishment
  • Hotel, guest house, B&B, youth hostel (30 and over bed spaces only, under 30 will be treated as households for enumeration purposes)
  • Other travel establishment
  • Other hostel or shelter establishment
  • Leisure / holiday establishment
  • Other establishment

CE Type 3:

  • Halls of Residence / student accommodation
  • Defence establishments (including ships)

CE Type 4:

  • Hostels and shelters for the homeless, and homeless people sleeping rough.

For CE Type 1, 2 and 4, paper questionnaires with an internet access code (except prisons) will be delivered to the establishment managers for issue to all usual residents.

For CE Type 3 Initial Contact Letters (two letters tailored to each type of establishment/respondent) with internet access codes will be delivered to establishment managers.

Census Area Managers will be allocated to a number of CEs and will provide support via telephone/email to CE managers throughout the collection period. CE managers will be asked to support and assist residents to complete their census if they need help.

Follow up support with CE managers will be carried out to ensure that an establishment questionnaire is completed, and where it has not been completed online or paper, it will be captured by telephone data capture using OCI.

There will be no follow up activity of individuals in communal establishments.
Individuals will be directed to the CE manager for help but they can also choose to use any of our support mechanisms if they prefer, including the contact centre or online help function.

An additional level of support will be available where it is clear that telephone contact is not sufficient and a visit to the establishment may be required. This will not be promoted, but considered on a case by case basis. Examples of this are care homes with vulnerable residents, or larger establishments where the respondent burden on the CE manager is affecting returns. Any instances of such access are expected to be rare and would be restricted to communal areas of the establishment.

The enumeration processes which directly impact on establishment staff and managers are illustrated below. This reflects the process for all CE Types, with the exception of CE 4 – homeless people sleeping rough.






Communications and engagement

February to March 2021

Social media messaging, in line with the census integrated communications and engagement strategy, designed to raise awareness of the census ahead of our initial contact.


Enumeration Address Check

Establishment check and initial engagement:

  • promote census
  • confirm establishment type
  • gather bed space and usual resident numbers
  • confirm contact details for manager.

Follow up phone calls will be made to non-responding establishments.

May to November 2021

Initial contact commenced by sending of letters and forms for completion to establishments.

All CEs on the CER will be contacted during the address check.


CE is allocated to a Census Area Manager. One to one relationship for the duration of census collect phase

January 2022

CEs will be allocated equally across all Area Managers.


CE Initial Contact:

  • Introduce themselves and provide CE manager with contact details
  • remind manager of census activity
  • verify establishment information
  • provide window for the courier delivery of Census Initial Contact Packs

31 January – 11 February 2022

Initial contact to the CE manager of each establishment by the allocated Census Area Manager by email or phone.

The delivery of census packs and the collection of questionnaires will take place by courier.


‘Contact In’ recorded in DCOMS

31 January – 11 February 2022

Area Manager records a ‘Contact In’ in DCOMS after initial contact is successfully completed.


Courier Delivery of Initial Contact Packs - to the CE manager

28 February – 4 March 2022

The courier will deliver the required material for enumeration directly to the establishment.

The packs are:

  • CE 1- Manager – ICL, individuals paper questionnaire with IAC.
  • CE 2 – Manager and individuals will receive paper questionnaires with internet access codes (except prison individuals – no IAC)
  • CE 3 – Manager and individuals will receive ICL’s
  • CE 4 – Manager (except rough sleeper hubs – no establishment questionnaire) and individuals will receive paper questionnaires with internet access codes.

A Listing Form will be provided in the manager packs to help managers to keep track of the distribution and collection of paper questionnaires (or confirmation of online completion).


Distribution of Census Initial Contact packs to residents

After courier delivery

The CE manager will distribute the individual initial contact packs to all usual residents of the establishment (as per Census Order and Regulations) and encourage completion, either by paper or online.

The CE manager will provide help and advice to residents.

The CE manager will complete or arrange for the completion of an individual questionnaire for any resident aged under 16 or otherwise incapable of doing so themselves


Follow up contact – establishment questionnaire

 16 March – 30 March 2022

Census Area Managers will conduct follow up contact to their assigned establishments by  phone and email to:

  1. Confirm completion of establishment questionnaire on paper and awaiting completion.
  2. Carry out TDC of establishment questionnaire using allocated IAC in OCI if not completed.
  3. Advise CE manager of collection window (except CE3 – no collection required).


Contact In Recorded in DCOMS

16 March – 30 March 2022

Census Area Manager records a Contact In in DCOMS after follow up contact is successfully completed.


CE manager preparation for collection (except CE 3)

Before collection window

The CE manager will collect all completed paper questionnaires - from residents before the scheduled collection date.

The CE manager will prepare the return package as per instructions provided.


Courier collection of questionnaires (except CE 3)

4 April – 8 April 2022

A courier will attend during the agreed collection window to pick up all completed - paper questionnaires and deliver to the paper capture site.

Communal Establishment Enumeration Type 1

Communal Establishment Enumeration Type 1 includes the following types of establishment:

  • Care homes with nursing
  • Care homes without nursing
  • Staff/worker accommodation
  • Religious establishments

The majority of usual residents in type 1 establishments are in care homes. In the 2011 Census, care homes had the highest number of usual residents of any communal establishment type (36,448 usual residents, which was 36.8% of the total communal establishment usual resident population). According to the Communal Establishment Register (CER) extract, August 2021, there were approximately 1,326 Type 1 establishments in the whole of Scotland. Exact numbers for 2022 will be determined during live operations.

The decision has been taken not to collect online responses from residents using a mobile device in CE Type 1 establishments.

As part of our stakeholder engagement, NRS continues to highlight the importance of CE managers and staff in raising awareness of the census. NRS also continues to encourage family members and those in support roles (e.g. carers, friends, relatives, legal guardians, powers of attorney) to assist with completion and response.

Communal Establishment Enumeration Type 2

Communal Establishment Enumeration Type 2 includes the following types of establishment:

  • General Hospital
  • Mental Health Hospital (including inpatient units)
  • Other Hospital
  • Other medical and care establishment
  • Prison and young offenders institution
  • Immigration Removal Centre
  • Children’s Home
  • School
  • Other educational establishment
  • Hotel, guest house, B&B, youth hostel (30 and over bed spaces only, under 30 will be treated as households for enumeration purposes)
  • Other travel establishment
  • Other hostel or shelter establishment
  • Leisure/ holiday establishment
  • Other establishment

Census responses for these types of establishment will primarily be collected using paper questionnaires. With the exception of prisons and detention centres, paper questionnaires for this group will include an Internet Access Code (IAC). This will enable online completion, if preferred.

In the 2011 Census there were 20,060 usual residents in 3,063 Type 2 communal establishments. The CER extract (August 2021) highlighted 2,727 establishments. Hotels, guest houses, B&Bs and youth hostels (30+ bed spaces) make up the majority of these establishments. They, however, have a low proportion of usual residents. In the 2011 Census only 4.1% of total bed spaces in hotels etc. were occupied by usual residents. Establishments like prisons have a very high proportion of usual residents.

Due to the nature of type 2 establishments there are a number of reasons for the chosen approach.

The establishment types and reasons are detailed below.

Prisons and detention centres

Due to residents in prisons and detention centres having limited access, if any, to the internet, an online approach would not be appropriate for this group. Paper questionnaires for residents in these establishments will not contain an internet access code.

Hotels, Guest Houses, B&Bs and Youth Hostels (30+ bed spaces)

The paper first approach was chosen for this group as there is a low proportion of usual residents in these establishments.

In Census 2011, hotels, guest houses, B&Bs and youth hostels were the category with the highest number of communal establishments (2,498), with an estimated 125,649 bed spaces. There was a total of 5,140 usual residents at these establishments, equating to only 4.1% of total bed spaces occupied by usual residents.

There is very little information available to NRS about the digital skills of usual residents in these establishments, unlike students in Type 3 accommodation, for whom there is a strong assumption of adequate digital skills. Therefore, NRS will supply a paper questionnaire with an IAC. The inclusion of an IAC on the paper questionnaire allows residents the option to complete online if that is their preference.

NRS will rely on the establishment manager’s understanding of who is considered a usual resident in the establishment. Clear guidance will be provided to the manager in the ‘Guidance Note for Managers’.

Any of these types of establishments with under 30 bed spaces will be treated as a household and receive a household questionnaire. This has been reviewed and agreed due to the low numbers of long term residents in these types of establishments who are not a family unit. Where it is identified that an address is a CE or business, it will be treated as such. As households, there is no business impact to consider.

Boarding Schools and Children’s Homes

The age of the residents in these establishments is the main reason for the paper first approach. Residents will mostly be under 18 years old, with the manager being responsible for making a return for those under the age of 16. Paper questionnaires allow the establishment manager to track responses and co-ordinate the enumeration process. 

Residents will have the option to complete online if they prefer. Again, clear guidance will be provided to managers, to explain their role in the enumeration process.

People under the age of 16, resident in either households or communal establishments, will be prohibited from completing individual questionnaire responses. Under the Census (Scotland) Order 2020, the making of a return for a child under 16 will (by default) be the responsibility of the Communal Establishment (CE) manager. This places legal responsibility upon the CE manager to provide a completed CE Questionnaire, either online or paper, and to sign and physically return any completed Communal Individual (CI) paper questionnaires. Although this does not mean that they necessarily have to fill in all the information on each individual questionnaire personally before the return is signed by whomever is operating on their behalf. The CE manager can arrange for a ‘relative or companion’ to complete the individual form on behalf of those under 16. 

No child under 16 will be able to make a return on their own behalf but they could provide answers to questions on an individual questionnaire and give that to the CE manager, who would be responsible for signing the declaration which states that the information provided in the form is, as far as they know, full and accurate. The CE Manager will be responsible for either completing the form themselves or at least placing themselves in a position where they can sign the declaration or making arrangements for a relative or companion to complete an individual form on behalf of the child. The manager will determine how best to encourage and ensure how returns are made for their CE.

Communal Establishment Enumeration Type 3

Communal Establishment Enumeration Type 3 includes the following types of establishment:

  • Halls of Residence / student accommodation
  • Defence establishments (including ships)

In the 2011 census there were 33,609 usual residents in 238 halls of residence.

Halls of residence have historically been a very difficult group to enumerate due to the demographic mix of residents, confusion around usual resident criteria and the complex nature of the establishments. This has resulted in previous censuses having lower than desired response rates.

This has influenced the approach for these establishments, and NRS believes that offering online completion for this group will help to improve response rates. Students most likely require reasonable digital skills to complete their studies, therefore there is a reasonable expectation that low digital skills will not be a barrier for completion. Stakeholder engagement has shown students prefer to complete administrative tasks online. Students’ engagement with their universities and learning establishments is also predominantly conducted through online channels.

There will be a need for the manager to issue out initial contact letters to each student and encourage completion; with the online approach, managers will not be expected to gather in completed responses.

To reduce the burden on the managers of these establishments, which tend to have high numbers of usual residents, NRS recommends across the board reminder emails are issued to all students once a week for four weeks, via the CE manager. The reminder email will be provided by the Census Area Manager to each CE they are responsible for. The CE manager will then share this with residents.

Census responses from these types of establishments will be encouraged to prioritise online completion using access to the OCI by individuals via their own device. If a resident prefers to complete their response on paper, then they will be able to request a paper questionnaire through the census contact centre or website.

Whilst the approach of direct postal contact to students had merit, in terms of the group being capable of self-response, it was agreed that room level data was difficult to verify across the varying types, and structure, of halls of residence. Other factors including: postal delivery methods, students regularly moving rooms in halls, and that a field force presence in a communal establishment of this structure would be difficult to manage, were also taken into consideration.

The approach to Armed Forces has been agreed with the Ministry of Defence (MoD). As of April 2020 the MoD have confirmed they are content with the approach NRS intends to use.

The decision has been taken not to carry out targeted non-response follow up visits in student halls of residence.

Communal Establishment Enumeration Type 4

Communal Establishment Enumeration Type 4 includes hostels and shelters for the homeless, and homeless people sleeping rough.

The enumeration approach for these types of establishment will be paper based. The paper questionnaires will have Internet Access Codes (IACs) so individuals can complete online if they prefer.

In the 2011 census, there was a total of 98 homeless people sleeping rough and 2,027 usual residents in 149 homeless hostels or shelters. The approach for homeless people sleeping rough in 2011 involved enumerators being present on streets for a selected night alongside a council worker. It is widely accepted that this produced a significant undercount and therefore this population group is a particular focus for 2022.

The CER extract (August 2021) highlighted 116 Type 4 hostels or shelters for the homeless.

Homeless people in temporary accommodation

The approach for Census 2022 is to conduct enumeration for homeless people in temporary accommodation (i.e. hostels and shelters) in line with the approaches used in enumerating other communal establishments.

Homeless people sleeping rough

NRS has developed the enumeration approach following engagement with colleagues in the Scottish Government and stakeholders in frontline services for homeless people. NRS will conduct the enumeration of rough sleepers in urban areas only i.e. cities. NRS will endeavour to identify one front line service in each of the seven cities of Scotland, using this as a base to carry out enumeration of homeless people sleeping rough.

The managers of these ‘hubs’ will not be required to complete an establishment questionnaire since it is not an overnight accommodation.

Volunteers working at the hub will issue, and collect, completed paper questionnaires to customers using their services. This will be done on 16th March 2022, as services are accessed more during the week. The volunteers will be provided with a guidance note to help them carry out this role.

The Census Area Manager will attend the enumeration hub on 16th March 2022 to support the hub manager and volunteers.

Sectors and groups affected

As above, the most significant anticipated impact relates to the managers of communal establishments.

For planning and operational purposes, four types of communal establishments have been identified, as detailed above.

The following types of establishment are in scope:

  • Care homes with nursing
  • Care homes without nursing
  • Hotels, Guest houses, B&Bs and youth hostels (30+ bed spaces only)
  • Other travel establishment
  • Leisure/holiday establishment
  • Staff/worker accommodation
  • Religious establishment
  • General hospital
  • Mental health hospital (including inpatient units)
  • Other hospital
  • Other medical and care establishment
  • Prison and young offenders institution
  • Immigration Removal Centre
  • Children’s home
  • School
  • Other Communal Establishment
  • Halls of residence / student accommodation
  • Other educational establishment
  • Defence establishments (including ships)
  • Hostel or shelter for the homeless
  • Other hostel or shelter establishment
  • Day services for rough sleepers


Whilst there is an enormous number of uses and related benefits of the census outputs, the most valuable can be categorised into two broad areas:

  • Supporting evidence based policy making and related research; and,
  • Informing the allocation, and targeting, of resources.

Data about general health, long-term conditions and long-term health problems or disability are used by central government, local governments and public bodies to identify health and social care service needs and to inform resource allocation at national and local level. It is also widely used to inform service planning and develop, monitor and assess policies on population health and health inequalities.

NRS calculated the cost to health board funding allocations if the census was not carried out in 2011. If census figures from 2001 had been used to make population estimates and allocate funding to health boards, in 2014/15 there would have been misallocations of between £30m and £40m. Some health boards would have received more, some less, than their appropriate share. (1)

With specific regard to Scotland’s business and commercial interests, census data outputs are equally valuable as a measure with which to inform market intelligence across a wide range of sectors, including: market research, data-mining, the financial sector, utilities, direct marketing and advertising and retail and leisure planning.

Footnotes for this section

  1. Scotland's Census 2011 General Report


Given the number of communal establishments in Scotland, the considerable variations in the sizes of establishment, the types of residents and the needs of enumeration processes, it would not be cost-effective to estimate the cost to business of the obligations conferred on communal establishment managers.

These obligations occur only once every ten years and extend to just a handful of communications, forms and visits. Effort is made to design census fieldwork practices in such a way as to minimise the burden which falls to establishment managers and staff, whilst maximising the level of response from establishment residents.

Scottish Firms Impact Test

In advance of the census, the enumeration team may visit a selection of communal establishments. This will increase our knowledge of user needs and provide the opportunity to share and discuss our approach with the establishment managers who will be taking part, and to obtain their feedback.

This engagement is intended to fulfil the requirements of the Scottish Firms Impact Test and feedback and results will be reflected in future iterations of the BRIA.

Competition Assessment

The four ‘Competition and Markets Authority’ (CMA) competition assessment questions, and the accompanying answers, below provide an assessment of competition.

Q: Will the proposal directly limit the number or range of suppliers?

A: No.

Q: Will the proposal indirectly limit the number or range of suppliers?

A: No.

Q: Will the proposal limit the ability of suppliers to compete?

A: No.

Q: Will the proposal reduce suppliers' incentives to compete vigorously?

A: No.

The census has no impact on competition in supply markets and will have minimal impact on business. NRS therefore considers that there is no requirement to complete a ‘Competition Assessment’ as part of the BRIA exercise.

Test run of business forms

Forms and questionnaires which will be used to support the 2022 census Communal Establishment enumeration operations are under development. Testing strategies will be undertaken in support of this work.

Legal Aid Impact Test

The Scottish Legal Aid Board has confirmed that it does not anticipate that Scotland’s Census 2022 will give rise to any impact on the provision of legal aid.

Enforcement, sanctions and monitoring

The exact legal obligations of communal establishment managers is provided in the Census (Scotland) Order 2020 and the Census (Scotland) Regulations 2020.

As noted above, there are set procedures for non-response follow-ups in respect of failure to supply the necessary information to facilitate enumeration of communal establishments.

Penalties which apply to non-compliance within the provisions of the Census Act 1920, the Census Order and the Census Regulations are set out in Section 8 of the Census Act 1920.

Implementation and delivery plan

Census Day is planned for Sunday 20 March 2022 and strategies and processes will reflect any testing and stakeholder feedback processes undertaken in advance of the census. Future iterations of this BRIA will provide an update on this work.

Post-implementation review

The arrangements for each census are set out in the Census Order and Census Regulations, including a statutory obligation to lay in Parliament a report the census returns. Our evaluation of Scotland’s Census 2022 will make recommendations for future censuses.

Summary and recommendation

In summary, the enumeration of communal establishments is essential to meet the requirements of the census and cannot be effectively achieved without the support and assistance of establishment managers, which is underpinned by their legal obligations as set out in census legislation.

Approaches, strategies and processes have evolved over many years and many censuses, but are subject to regular review and improvement with the input of those impacted.

NRS is confident that the intended approach will be successful and that the burden the census places on communal establishment managers and staff is both reasonable and proportionate in the context of an operation usually run every ten years.

Declaration and publication

I have read the Business and Regulatory Impact Assessment and I am satisfied that, given the available evidence, it represents a reasonable view of the likely costs, benefits and impact of the leading options. I am satisfied that business impact has been, and will continue to be, assessed with the support of businesses in Scotland.

Signed: Angus Robertson

Title: Cabinet Secretary for the Constitution, External Affairs and Culture

Date: 2 December 2021

Annex A - Legal obligations – Census (Scotland) Order 2020

Census (Scotland) Order 2020

 Persons by whom the returns are to be made:

5 - (1) Where a dwelling is occupied by a household consisting of one person in Group I, that person must make a return with respect to that person and every visitor at that dwelling.

(2) Where a dwelling is occupied by a household consisting of more than one person in Group I a return must be made with respect to every person in Group I and every visitor at that dwelling.

(3) Subject to paragraph (12), a return under paragraph (2) is to be made by—

(a) the householder, or

(b) if there is no householder or the householder is unable to make the return, the members of that household aged 16 years or over on census day.

(4) Any person with respect to whom a return falls to be made in accordance with paragraph (2) may elect to make an individual return with respect to that person if the person is—

(a) aged 16 years or over on census day,

(b) capable of completing the form of return, and

(c) not a visitor.

(5) A person (“A”) who has, in accordance with paragraph (4), elected to make an individual return—

(a) may, but need not, notify the person making the return under paragraph (2) that A has so elected, and

(b) must make the individual return.

(6) In the case of any premises in Group II, III, IV or V, the manager, chief resident officer, director or governor, or other person for the time being in charge of the premises and in the case of any premises in Group VI the commanding officer or other person for the time being in charge of the premises, must make a return.

(7) Every person in Groups II, III, IV, V, VI and, subject to paragraph (8), Group VII must make an individual return, but where any such person is not aged 16 years or over or is, for any other reason, incapable of making a return and that person is—

(a) a person in Group II, then the manager or other person for the time being in charge of the hotel or guest house must make a return with respect to that person or arrange for it to be made by a relative or other person accompanying that person,

(b) a person in Group III or IV, then the chief resident officer or other person for the time being in charge of the premises must make the return with respect to that person or arrange for it to be made by a relative or companion of that person,

(c) a person in Group V, then the director or governor or other person for the time being in charge of the premises must make a return with respect to that person or arrange for it to be made by a member of staff of the owner of the establishment,

(d) a person in Group VI, then the return must be made with respect to that person by the commanding officer or other person for the time being in charge of the premises,

(e) a person in Group VII, then the return may be made with respect to that person by any other person capable of doing so on his or her behalf.

(8) As regards a person in Group VII who is capable of making a return, the return referred to in paragraph (7) may be made by any other person authorised by that person to do so on that person’s behalf.

(9) Subject to paragraphs (10) to (12), in the case of a dwelling in Group VIII, the householder must make a return with respect to the person in Group VIII and every visitor at that dwelling.

(10) A return need not be made under paragraph (9) if, in relation to the dwelling to which the return relates, either or both of the following apply—

(a) for a period of 6 months or more ending with census day, no person has stayed or lived at the dwelling,

(b) the householder expects that, for a period of 6 months or more including census day, no person will stay or live (or will have stayed or lived) at the dwelling.

(11) The return referred to in paragraph (9) may be made by any person authorised by the householder to make the return or by any visitor staying at the dwelling on census night.

(12) The obligation to make a return under paragraph (2) or (9) is satisfied if, as the case may be, any householder or member of the household mentioned in paragraph (3)(b) makes such a return.

Annex B - Definitions/classifications from Census (Scotland) Order 2020


(1) Premises or other place

(2) Persons


Any dwelling occupied by a household. Every person who is usually resident in the dwelling.


Any hotel or guest house, not being a dwelling occupied by a household, and excluding any part of the premises which constitutes such a dwelling. Every person who is usually resident in the premises and who has not been included in any other return in the United Kingdom.


Any hospital, nursing home, religious or charitable community or other residential establishment whatsoever, not being a dwelling or an establishment mentioned elsewhere in this schedule, and excluding any part of the premises which constitutes a dwelling or establishment so mentioned. Every person who is usually resident in the premises and who has not been included in any other return in the United Kingdom. 


Any residential school, college or other educational establishment, not being a dwelling occupied by a household, and excluding any part of the premises which constitutes such a dwelling.  Every person who is usually resident in the premises.


Any civil prison or other place of detention. Every person who is usually resident in the premises and who has not been included in any other return in the United Kingdom. 


Any barracks, station or other premises under naval, military or air force discipline. Every person who is usually resident in the premises and who has not been included in any other return in the United Kingdom.


Every person usually resident in Scotland but not usually resident at any dwelling or premises mentioned elsewhere in this schedule and who has not been included in any other return in the United Kingdom.


Any residential dwelling which is not occupied by a household consisting of persons in Group I. The householder or, if there is more than one householder, one of those householders.