News

“The inequalities we talk about are not a secret” Module 7 of the Covid-19 Inquiry examines the adequacy of the Test, Trace and Isolate system, including its impact on minority ethnic communities, during the pandemic

After three weeks of oral evidence, Module 7 of the UK Covid-19 Inquiry concluded on 30 May 2025. This module considered the policies developed, and strategies implemented, as part of the Test, Trace and Isolate (“TTI”) system across the United Kingdom during the pandemic. This included an examination of whether the system was fit for purpose, and the impact of its rollout. The evidence heard will feed into recommendations on future pandemic preparedness in respect of TTI.

Saunders Law represents the Federation of Ethnic Minority Healthcare Organisations (‘FEMHO’).  FEMHO’s key concerns in Module 7 centred around how the development and implementation of TTI policies adversely impacted those from ethnic minority backgrounds. For example:

  • Barriers to participating in each aspect of the TTI system, including the inadequacy of financial support for self-isolation
  • The lack of meaningful engagement with a diverse range of stakeholders in the development of the TTI system
  • The absence of clear, culturally competent messaging in communicating TTI policies
  • The lack of systems to collect and disaggregate data by race and ethnicity, such that it could be analysed to evaluate the impacts of TTI strategies on specific population groups
  • The disproportionate enforcement of Covid-19 Regulations, including in relation to TTI, against minority ethnic communities
  • The fact that these inequalities were entirely foreseeable

The public hearings opened as usual with a short impact film, shown to contextualise the purpose of these hearings by means of individual stories and experiences of those impacted by the pandemic. Opening statements were then delivered by Counsel to the Inquiry and Core Participants. This was followed by 12 days of live witness evidence, and the proceedings concluded with closing submissions by Core Participants.

The Inquiry heard evidence from senior scientific, ministerial, technological and operational figures involved in the pandemic response, as well as three independent experts. The evidence shed light on various failures in respect of the TTI system, including:

  • The limited accessibility and reach of testing in the early stages of the pandemic. Although there was purported intent for testing systems to reach all communities, the practical infrastructure to do so equitably was either underdeveloped or deployed too late.
  • The inadequacy of financial support for self-isolation, which inevitably impacted adherence to TTI behaviours.
  • Issues with data collection and evaluation, which has been a consistent theme throughout the Inquiry. There was broad recognition of the need for more inclusive data collection and for systems that account for linguistic, cultural, and socioeconomic barriers.
  • The disproportionate enforcement of Covid-19 regulations against ethnic minority communities. Martin Hewitt, Chair of the National Police Chiefs’ Council, gave evidence that he was attune to “the challenge that policing has in its relationship with minority communities”, and foresaw how the role of race and ethnicity could impact upon enforcement. Though he liaised with government about this, he was unable to identify any specific steps taken to address the issue.
  • Witnesses recognised the fundamental importance of building and maintaining trust with communities who are marginalised and historically distrustful of government. Although some engagement efforts during the Covid-19 pandemic were described, these efforts often came too late and failed to translate into meaningful input at the strategic level.

A key takeaway from the evidence in Module 7 was that, while the pandemic did not create structural racism, it intensified the existing conditions that contributed to the disproportionate negative experiences of Black, Asian and Minority Ethnic communities – such as economic inequalities, overcrowded housing, and insecure employment.

It is clear that the knowledge of these pre-existing structural inequalities should have informed the pandemic response, though sadly, it did not. The TTI system is a stark illustration of the lack of adequate planning and strategy to mitigate the foreseeable impacts of structural racism, as it not only exposed, but also served to deepen these inequalities.

Philip Dayle delivered FEMHO’s oral closing statement. FEMHO focused its Module 7 recommendations on the following areas, which require serious and urgent consideration to rebuild trust and ensure preparedness for a future pandemic:

  • There is scope to build up an outreach platform for TTI during “peacetime”. Such a platform needs to become a part of future pandemic preparedness that targets Black, Asian and Minority Ethnic communities.
  • It is important to professionalise the role of minority ethnic healthcare workers in providing access to their communities. Their involvement should not be merely ad hoc or situational, but well thought-out, systematic and remunerated.
  • Planning across the health sector should incorporate a focus on how best to utilise representative stakeholders from all levels of the sector, to systematically and proactively engage in the development and implementation of systems like TTI.

Public inquiries present a unique opportunity to learn from past injustices, and make recommendations to avoid similar injustices occurring in future. Despite being disproportionately impacted by Covid-19, minority ethnic communities experienced the full force of the government’s failures in developing, communicating and implementing the TTI system. Looking forward, FEMHO maintains that it is crucial for the insights from Module 7 to be treated as an opportunity for structural inclusion. The work of groups like FEMHO was instrumental in building trust during the pandemic, and it is important that this work becomes embedded in the design of public health policy in future emergencies.

We offer expert legal assistance and representation in public inquiries and are well-known for our work and thorough approach to complex cases. Please contact us on +44(0)207 632 4300, or fill in our online enquiry form if you would like our assistance and we would be happy to discuss your matter with you.

    Close

    How can we help?

    Please fill in the form and we’ll get back to you as soon as we can





    We have partnered with Law Share from JMW Solicitors LLP to refer instructions and clients to them, when we are unable to act. By answering yes to this question, you agree that we may pass your details on to Law Share in such circumstances. You are under no obligation to instruct JMW Solicitors LLP after being referred. We may receive a payment from JMW Solicitors LLP further to this referral.