Consultation Submissions

Here we publish our submissions to Scottish and UK Government consultations, as well as any other consultations we feel it’s important for our voices to be heard.


Scottish Parliament: Equalities, Human Rights and Civil Justice Committee
Gender Recognition Reform (Scotland) Bill: Call for Views

Remit: Provide comment on the Bill to help inform the scrutiny of the Committee.

Date submitted: 16 May 2022
Submission: PDF


Scottish Government
Public Sector Equality Duty review

Remit: The Scottish Ministers are seeking views on specific and detailed proposals within the Scottish Specific Duties which are aimed at improving the current regime. Further and general views from stakeholders are also invited.

Date submitted: 11 April 2022
Submission: PDF


United Nations Human Rights Council
Universal Periodic Review

Remit: The Universal Periodic Review (UPR) is a unique process which involves a review of the human rights records of all UN Member States. The UPR is a State-driven process, under the auspices of the Human Rights Council, which provides the opportunity for each State to declare what actions they have taken to improve the human rights situations in their countries and to fulfil their human rights obligations. The UK will be reviewed for its fourth cycle in November 2022. All relevant stakeholders can submit written information which is considered during the review.

Date submitted: 29 March 2022
Submission: PDF


UK Government
Banning Conversion Therapy

Remit: Gathering views on aspects of the policy including: targeting physical acts conducted in the name of conversion therapy; targeting talking conversion therapy with a new criminal offence; and producing a package of holistic measures, such as Conversion Therapy Protection Orders, new support for victims, restricting promotion, removing profit streams, and strengthening the case for disqualification from holding a senior role in a charity. 
In some areas the questions are specific, to gather reactions to the preferred approach, while in others the questions are more open, to gather stakeholder views and further evidence.

Date submitted: 04 February 2022
Submission: PDF


Financial Conduct Authority

Remit: The FCA invited views on their consultation paper on diversity and inclusion on company boards and executive committees. This included setting a target for at least 40% of boards to be women (including individuals self-identifying as women).

Date submitted: 20 October 2021
Submission: PDF


Equality and Human Rights Commission

Remit: The EHRC invited views on their draft strategic plan for 2022-25.

Date submitted: 29 September 2021
Submission: PDF


Scottish Government
Views on ‘Accurately record the sex of people charged or convicted of rape or attempted rape’
petition

Remit: The Equalities, Human Rights and Civil Justice Committee invited views on a public petition, PE1876: Accurately record the sex of people charged or convicted of rape or attempted rape

Date submitted: 28 September 2021
Submission: PDF


Scottish Government
Views on the ‘End Conversion Therapy’ petition

Remit: The Equalities, Human Rights and Civil Justice Committee invited views on a public petition, PE1817: End Conversion Therapy.

Date submitted: 12 August 2021
Submission: PDF

Additional information:
– 14 March 2022 Our letter to the Committee published.


United Nations Commission on the Status of Women

Remit: Communications (complaints/appeals/petitions) to the Commission on the Status of Women containing information relating to alleged violations of human rights that affect the status of women in any country in the world. The Commission on the Status of Women considers such communications as part of its annual programme of work in order to identify emerging trends and patterns of injustice and discriminatory practices against women for purposes of policy formulation and development of strategies for the promotion of gender equality.

Date submitted: 01 August 2021
Submission: Our response covered the Gender Representation on Public Boards Act, All-Women Shortlists, Census, Hate Crime and Public Order Act, Prisons, and the Genuine Occupation Requirement.
Submission: PDF
Also published as stand alone chapters, starting here.


Working Group on Misogyny and Criminal Justice in Scotland

Remit: There is no agreed definition of misogyny in Scotland currently. The Working Group have agreed a working definition to help in identifying misogynistic behaviours – this is deliberately not a legal definition and is as follows:
Misogyny is a way of thinking that upholds the primary status of men and a sense of male entitlement, while subordinating women and limiting their power and freedom. Conduct based on this thinking can include a range of abusive and controlling behaviours including harassment and bullying. Misogyny can be conscious or unconscious, and men and women both can be socialised to accept it.
Written Evidence Questions:
1. Which conduct do you consider to be covered by the term misogynistic behaviours?
2. Do you know of any Scottish laws that currently address misogynistic behaviours?
3. Do the current laws adequately protect women in Scotland from misogynistic behaviours?
4. Are there any gaps in the law in Scotland regarding misogynistic behaviours?
5. Do you think there should be a stand – alone offence to cover misogynistic behaviour in public spaces including the street, around schools, on public transport, online etc.?
6. Do you think that the characteristic of ‘sex’ should be added to hate crime legislation in Scotland?
7. Do you think that there should be an offence of stirring up of sexual hatred added to hate crime legislation in Scotland? ​
8. What non-legal measures are you aware of that have attempted to address misogynistic behaviours within Scottish society?
9. How effective, in your view, have these non-legal measures been in addressing these behaviours?
10. Should any of these non-legal measures be made mandatory?

Date submitted: 30 July 2021
Submission: PDF


UK Government
Toilet provision for men and women

Date submitted: 25 February 2021
Submission: PDF


Scottish Government
Hate Crime and Public Order (Scotland) Bill

Date submitted: 22 February 2021
Submission: PDF


Scottish Government
Sex and Gender in Data Working Group: Feedback on Draft Guidance
Date submitted: 12 February 2021
Submission: PDF
Additional information: Also a blog post


UK Government
Law Commission: Hate Crime
Date submitted: 24 December 2021
Submission: PDF


Scottish Government
Challenging Men’s Demand for Prostitution
Date submitted: 10 December 2020
Submission: PDF


Parliament of Canada
Federal Bill C-6 Conversion Therapy
Date submitted: 06 December 2020
Submission: PDF


Scottish Government
United Nations Convention on the Rights of the Child (Incorporation) (Scotland) Bill
Date submitted: 16 October 2020
Submission: PDF


Scottish Government
Post-legislative Scrutiny: The Lobbying (Scotland) Act 2016

Date submitted: 14 August 2020
Submission: PDF


Scottish Government: Justice Committee
Hate Crime and Public Order (Scotland) Bill: Call for Views

Date submitted: 19 July 2020
Submission: PDF

Additional information:
– 20 November 2020 Supplementary Evidence
– 24 November 2020 Susan Smith, FWS giving evidence to the Justice Committee (Official Report and Video)
– 30 November 2020 Supplementary Evidence
– 16 February 2021 Supplementary Evidence
– 22 February 2021 Freedom of Expression Amendments (Remit): Submission


Scottish Government
Forensic Medical Services (Victims of Sexual Offences) (Scotland) Bill

Date submitted: 26 June 2020 Letter to Health and Sport Committee

Additional information:
– Several blog posts
– 10 December 2020 Stage 3 Debate and Vote (Official Report and Video)


Scottish Government
Gender Recognition Reform (Scotland) Bill: A Consultation

Date submitted: 17 March 2020
Submission: PDF
Additional information: Also a blog post


Scottish Human Rights Commission
Scotland’s second National Action Plan for Human Rights (SNAP2)

Date submitted: 16 December 2019
Submission: PDF


National Advisory Council on Women and Girls
September 2019 Spotlight on Sport

Date submitted: 24 September 2019
Submission: PDF


Scottish Rugby
Transgender Policy: Non-Binary Players

Date submitted: 31 August 2019
Submission: PDF


Scottish Government: Equalities and Human Rights Committee
Draft Budget Scrutiny 2020-21: Call for Views

Date submitted: 23 August 2019
Submission: PDF

Additional information: 26 September 2019 Susan Smith, FWS giving evidence to the Equalities and Human Rights Committee (Official Report and Video)


Scottish Government
Consultation on Implementation of the Gender Representation on Public Boards (Scotland) Act 2018

Date submitted: 04 August 2019
Submission: PDF


Scottish Government
Consultation on Scottish Hate Crime Legislation

Date submitted: 24 February 2019
Submission: PDF


Scottish Government: Culture, Tourism, Europe and External Affairs Committee
Census (Amendment) (Scotland) Bill: Call for Views

Date submitted: 23 November 2018
Submission: PDF

Additional information: 06 December 2018 Susan Smith, FWS giving evidence to the CTEEA Committee (Official Report and Video)