The scattering theory of low-energy (slow) electrons has been developed by Evans and Mills [Phys. Rev. B 5, 4126 (1972)]. The formalism is merely based on the electrostatic Coulomb interaction of the scattering electrons with the charge-density fluctuations above the surface and can describe most of the interesting features observed in the high-resolution electron energy-loss spectroscopy experiments. Here we extend this theory by including the spin-orbit coupling in the scattering process. We discuss the impact of this interaction on the scattering cross section. In particular, we discuss cases in which a spin-polarized electron beam is scattered from nonmagnetic surfaces with a strong spin-orbit coupling. We show that under some assumptions one can derive an expression for the scattering cross section, which can be used for numerical calculations of the spin-polarized spectra recorded by spin-polarized high-resolution electron energy-loss spectroscopy experiments.