Equality and Health Inequalities Impact Assessment (EHIA): NHS Notify

NHS Notify

NHS Notify is a live service run by NHS England (NHSE), this EHIA has been completed retrospectively. This service enables health and social care organisations to communicate with patients and the public via NHS App messages, emails, texts and letters to patients and the public.

NHS Notify is also integrated with the Personal Demographics Service (PDS), which allows it to:

• enrich data received from health and social care organisations (NHS numbers) with a person’s contact information
• prevent sending messages to people who cannot, or should not, be contacted.

NHS Notify does not create or process message content. Sending programmes are responsible for accessibility compliance. They meet this obligation by providing accessible templates and instructing NHS Notify to apply them to recipients with accessible format requirements. Information regarding these communication preferences and accessible format requirements is obtained from the Personal Demographics Service (PDS) or the sending programme.

Where a recipient has a specific need and the sending programme has provided the corresponding template, NHS Notify will use that template, if no accessible template has been provided the recipient receives the standard template.

The service supports accessible formats (opens in a new tab).

The purpose of this EHIA is to:

• assess the impact of the NHS Notify service on protected characteristic groups and people at particular risk of health inequalities
• recommend actions where an adverse impact has been identified

Through sending messages digitally, we can support a wider range of accessibility needs and meet legal requirements through nationally consistent standards for how communications are sent. However, where digital channels are not successful in communicating with patients, NHS Notify has the ability to ‘fallback’ to physical communication methods (letters). 

Age: older people; middle years; early years; children and young people

NHS Notify doesn’t make an exception to people based on age.

NHS Notify already services these age groups in the Vaccinations campaign. The service has successfully delivered Flu, Covid, MMR and RSV campaigns. Children are not contacted directly; the communication is sent to the parent / carer of the children. 

Age groups are identified by sending programmes using cohorting, and patients/citizens can be specifically contacted by NHS Notify when age is a factor in a patient’s care.

The programme sending the communication will advise on age group cohorts and the route to be used. We can send messages in the format required.

NHS Notify can only contact a parent/carer or otherwise responsible person if the NHS number of that person is provided. We cannot derive the proxy from PDS. 

No adverse impact has been identified as we provide four channels: NHS App, SMS, email and letters.

It’s the responsibility of the sending programme to consider any requirements related to age.

The sending programme to integrate with Proxy service to accurately identify the patient and their responsible person

Recommendation: No recommendations identified

Disability: any long-term physical or mental impairment; substantially effecting day-to-day activities

NHS Notify does not distinguish between patients based on their disability.

NHS Notify checks for recipients who need letters in accessible formats using the Personal Demographics Service (PDS). 

22% of people in the UK (14.6m people) reported a disability in 2020/21. 42% of working-age adults reported a mental health impairment in 2020/21. In each of the three years to 2020/21, mobility was the most prevalent impairment reported. 63% of disabled State Pension age adults reported a mobility impairment compared to 15% of children. 

Working-age adults were the most likely group to report mental health impairments.

People with disabilities are significantly less likely to own a smartphone or access the internet. A large proportion of disabled people offline are over the age of 70.

NHS Notify can also send communications in the form of SMS messages and letters, therefore mitigating some of these issues.

NHS Notify checks for recipients who need letters in accessible formats using the Personal Demographics Service (PDS).

It’s the responsibility of the sending programme to consider any requirements related to disability and accessibility.

NHS Notify also offers large print, braille, audio CDs. If the sending programme can provide an audio link, that can be sent in the message.

Links can be included to take recipients to other accessible formats such as British Sign Language (BSL) and Easy read. The senders need to arrange these accessible formats, NHS Notify does not provide them. 

No adverse impact.

Recommendation: No recommendations identified.

Gender reassignment and/or people who identify as trans

NHS Notify does not distinguish between patients based on their gender. 

We are not aware of any information that suggests that NHS Notify services would have a disproportionate impact on patients by gender.

NHS Notify gets officially recorded gender data, but we don’t consider it for purposes of message delivery.

It’s the responsibility of the sending programme to consider any requirements related to gender reassignment to make this easier NHS Notify has the ability to address letters without honorific titles, therefore reducing the impact of using a misaligned title in a health record, to those who have changed their honorific title. However, the choice to include honorific titles in messages even if present is set by the sending programme.

Recommendation: No recommendations identified.

Marriage and civil partnership : people married or in a civil partnership

NHS Notify does not distinguish between patients based on their marriage and civil partnership status. We do not get marriage and civil partnership status from PDS. 

We are not aware of any information that suggests that NHS Notify services would have a disproportionate impact on patients by marriage and civil partnership. 

The title if used to send the messages is taken from the PDS system therefore the patient has chosen the appropriate title. 

It’s the responsibility of the sending programme to consider any requirements related to marriage and civil partnership.

Recommendation: No recommendations identified.

Note: In relation to this protected characteristic a public authority subject to the PSED need only comply with the duty to have due regard to the need to eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under the EqA 2010, but not advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it. 

Pregnancy and maternity: women while pregnant and during maternity leave

To date, we do not have any evidence that this group would be impacted differently or adversely by NHS Notify services. 

It’s the responsibility of the sending programme to consider any requirements related to pregnancy and maternity.

Recommendation: No recommendations identified.

Race and ethnicity : including nationality language where intrinsically linked to nationality

NHS Notify does not distinguish between patients based on race and ethnicity. We do not get race and ethnicity status from PDS. 

NHS Notify can support programmes to communicate appropriately with people of different ethnicity should they have a need for a non-English language in PDS. NHS Notify can send translations for non-English languages. Twenty-eight languages are supported by NHS Notify. The sending programme needs to supply the translated content that is to be sent to the citizen / patient. 

Non-English language translated letters can be sent. But language translations cannot be sent in digital formats. A recommendation has been added. 

It’s the responsibility of the sending programme to consider any requirements related to race and ethnicity.

Recommendation: It is recommended that NHS Notify investigates and implements the option to send non-English language translated content in NHS App, SMS and email formats.

Note:  Addressing racial inequalities is about identifying any ethnic group that experiences inequalities. Race and ethnicity includes people from any ethnic group incl. BME communities, non-English speakers, Gypsies, Roma and Travelers, migrants etc. who experience inequalities so includes addressing the needs of BME communities but is not limited to addressing their needs, it is equally important to recognise the needs of White groups that experience inequalities. The Equality Act 2010 also prohibits discrimination on the basis of nationality and ethnic or national origins, issues related to national origin and nationality.

Religion and belief: people with different religions/faiths or beliefs, or none

NHS Notify does not distinguish between patients based on religion and belief. We do not get race, religion and belief information from PDS. 

It’s the responsibility of the sending programme to consider any requirements related to religion and belief.

Recommendation: No recommendations identified.

Sex: men, women

NHS Notify does not distinguish between patients based on their sex. NHS Notify does get data relating to a persons recorded gender from PDS we do not use it for the purposes of communicating with patients.

We are not aware of any information that suggests that NHS Notify services would have a disproportionate impact on patients by not collecting data on sex.

The title if used to send the messages is taken from the PDS system.

It’s the responsibility of the sending programme to consider any requirements related to sex.

Users can choose to remove their honorific title from their GP / PDS record. The choice to include honorifics in messages even if present is set by the sending programme.

Recommendation: No recommendations identified.

Sexual orientation: lesbian; gay; bisexual; heterosexual

NHS Notify does not distinguish between patients based on their sexual orientation. We do not get data on sexual orientation from PDS.

We are not aware of any information that suggests that NHS Notify services would have a disproportionate impact on patients by not collecting data on sexual orientation.

It’s the responsibility of the sending programme to consider any requirements related to sexual orientation.

Recommendation: No recommendations identified.

NHS Notify can send communications in the following formats: NHS App, emails, SMS and letters. The routing configuration (fall back) is provided by the sending programme. E.g. If the NHS App message is not read to send a SMS. 

NHS Notify service supports accessible formats (opens in a new tab). NHS Notify also offers large print letters, braille letters and audio CDs. 

We can add links to audio files, easy read and British Sign Language (BSL). We can send language translations in twenty eight languages. The accessible content needs to be provided by the sending programme.

It’s the responsibility of the sending programme to consider any requirements related to disability and accessibility and provide accessible content to NHS Notify. 

We also can address letters without honorific titles, therefore reducing the impact to those who have changed their honorific title, however the choice to include honorifics in messages even if present is set by the sending programme.

Many groups who share protected characteristics have also been identified as facing health inequalities.

Looked after children and young people

NHS Notify can only contact a parent/carer or otherwise responsible person if the NHS number of that person is provided. At the present time, proxy cannot be set up for a responsible person to receive communications. 

NHS Notify does not distinguish between patients based on their looked-after status. 

The sending programme to integrate with Proxy service to accurately identify the patient and their responsible person.

No adverse impact. 

Recommendation: No recommendations identified.

Carers of patients: unpaid, family members

NHS Notify can send communications to carers of patients, we rely on the sending programme to advise the responsible person details.

At the present time, proxy cannot be set up for a responsible person to receive communications.

The sending programme to integrate with Proxy service to accurately identify the patient and their responsible person.

Recommendation: No recommendations identified.

Homeless people: people on the street; staying temporarily with friends /family; in hostels or B&Bs

There is a risk that this cohort may not have access to a smartphone and may not be able to access the NHS App and email from a phone. However, as NHS Notify can send SMS, and letters, we can contact them through these mechanisms.

Individuals living in temporary addresses can receive invites to the address recorded on PDS. NHS Notify has established a process to return undelivered letters.

In some cases, GP practices also have communications sent to them, so they can pass on the communications to the patients when they next visit the practice.

It’s the responsibility of the sending programme to consider any requirements related to the cohort.

No adverse impact.

Recommendation: No recommendations identified.

People involved in the criminal justice system: offenders in prison/on probation, ex-offenders

NHS Notify does not distinguish between patients based on their criminal record status. 

The people in prison would not have access to phone, smart phones or emails.

They are on their own health system. 

The prison’s contact address can be updated as the address for prisoners to receive letter correspondence. Its sending programmes choice if they wanted to send a letter to prison to indicate a detainee required screening etc. 

A copy of any letter will be sent to the NHS App for them to access when they have access.

Recommendation: No recommendations identified.

People with addictions and/or substance misuse issues

NHS Notify does not distinguish between patients based on their addictions and /or substance misuse issues. 

No adverse impact. 

Recommendation: No recommendations identified.

People or families on a low income 

NHS Notify does not distinguish between patients based on their low-income status.

No adverse impact. 

Recommendation: No recommendations identified.

People with poor literacy or health literacy: (such poor understanding of health services poor language skills)

NHS Notify offers large print, braille, audio CDs, and audio file links. Links to easy read content also can be sent, the content needs to be provided by the sending programme.

Additionally, translated content can be sent in twenty eight languages, the content needs to be provided by the sending programme.

No adverse impact.

Recommendation: No recommendations identified.

People living in deprived areas

NHS Notify does not distinguish between patients based on the area they live in.

No adverse impact.

Recommendation: No recommendations identified.

People living in remote, rural and island locations

NHS Notify does not distinguish between patients based on where they live.

No adverse impact.

Recommendation: No recommendations identified.

Refugees, asylum seekers or those experiencing modern slavery

NHS Notify does not distinguish between patients based on their immigration status.

NHS Notify can send translations for non-English languages. Twenty-eight languages are supported by NHS Notify. Its the sending programmes responsibility to send the translated content that is to be sent to patients with a language requirement in PDS.

Non-English language translated letters can be sent. But language translations cannot be sent in digital formats, a recommendation has been added.

Recommendation: It is recommended that NHS Notify investigates and implements the option to send non-English language digital translated content in NHS App, SMS and email formats.

People who are digitally excluded, or digitally illiterate: people who have little or no access to digital devices or internet connection, or who lack the skills and knowledge to use digital devices, processes and systems 

NHS Notify does not distinguish between patients based on their digital skills. 

NHS Notify is able to send letters, this is a valuable feature that supports inclusion. NHS Notify can also send translated content is twenty-eight non-English languages. 

No adverse impact.

Recommendation: No recommendations identified.

Other groups experiencing health inequalities

Children and adults living in care homes. The sending programme needs to provide the details of the responsible person to send the comms.

No recommendations identified for NHS Notify but needs to be looked into by Messaging.

Recommendation: No recommendations identified.

As NHS Notify provides NHS App, emails, SMS, letters and accessible formats, the risks are mitigated. But a few recommendations have been identified to give a better outcome. The Messaging workstream is also working on reducing barriers and digital inclusion for the whole of the Messaging remit.

Language translations are provided in letter format, we have identified that it would be good to provide in NHS App, SMS and email formats, so that patients can use assistive technology to read the messages. Work has commenced to look into this requirement. 

Currently, NHS Notify does not conduct accessibility testing on features before their release. It is recommended that accessibility testing be integrated into the testing process. Testers with accessibility testing skills should be recruited, and utilise the accessibility lab at NHSE for this purpose.

Although NHS Notify has conducted an internal accessibility audit, it is advisable to engage an independent external assessor to ensure there are no accessibility issues.

The language translations recommendation mentioned about would also help to reduce inequalities. We are planning to do some user research as part of the Messaging work to assess if further improvements can be made. 

The Messaging EHIA has also been drafted and includes additional recommendations. As part of the Messaging workstream, efforts are underway to provide evidence-based best practices to help senders construct effective communication plans. Additionally, a means for NHS Notify to use needs-based social adjustments is being implemented, and these will be covered in the Messaging EHIA.

Have any key engagement or consultative activities been undertaken that considered how to address equalities issues or reduce health inequalities? 

No

If yes, please briefly list up the top 3 most important engagement or consultation activities undertaken, the main findings and when the engagement and consultative activities were undertaken. 

N/A as NHS Notify a tool to send communications. It is the programmes responsibility to do the consultation activities. 

Explanation

NHS Notify offers large print, braille, audio CDs, and audio file links. Additionally, we offer translations in twenty-eight languages for letters. We also supply messaging across a range of channels (from digital to paper) to meet the varied needs of our recipients, enabling them to receive communications in a format they can access.

Explanation

NHS Notify provides four communication channels, ensuring quick contact through routing configuration. It offers large print, braille, audio CDs, and audio file links. Additionally, translations are available in twenty-eight non-English languages.

N/A

We have evaluated the NHS Notify services against the nine protected characteristics and health inequalities, some recommendations have been identified.

NHS Notify offers four different channels for communication: the NHS App, emails, SMS, and letters, ensuring there is a format suitable for everyone.

NHS Notify checks for recipients who need letters in accessible formats using the Personal Demographics Service (PDS). Additionally, NHS Notify offers large print, braille, audio CDs, and audio file links. Links can be added to easy read and British Sign Language (BSL) formats, accessible content needs to be provided by the sending programme. 

NHS Notify also provides translations in twenty-eight non-English languages. Non-English language translated letters can be sent. But language translations cannot be sent in digital formats.

The Messaging EHIA has also been drafted and includes additional recommendations. As part of the Messaging workstream, efforts are underway to provide evidence-based best practices to help senders construct effective communication plans. Additionally, a means for NHS Notify to use needs-based social adjustments is being implemented, and these will be covered in the Messaging EHIA.

NHS Notify does support people with accessibility needs, a few recommendations have been identified to help reduce barriers and reduce digital exclusion. 

Recommendations

NHS Notify to investigate and implement the option to send non-English language digital translated content in NHS App, SMS and email formats.

Integrate accessibility testing into the testing process. 

Testers with accessibility testing skills should be recruited, and utilise the accessibility lab at NHSE for this purpose.

Conduct an external accessibility audit and get feedback on the accessibility statement from the external reviewer.

Email: [email protected]

Date EHIA agreed: 17 December 2025