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.
United Nations CEDAW: Equal and inclusive representation of women in decision-making systems
Remit: On 22 February 2023 the Committee on the Elimination of Discrimination against Women will hold a half-day of general discussion on “Equal and inclusive representation of women in decision-making systems”. The Committee invited written submissions on the theme of the general discussion.
Date submitted: 17 February 2023
Submission: PDF
Scottish Government: Equality Evidence Strategy 2023-25
Remit: Seeking views to shape the draft plan to improve and strengthen Scotland’s equality evidence base. The development of Scotland’s next Equality Evidence Strategy, covering the years 2023 to 2025 will enable policy makers to develop sound and inclusive policies to improve service delivery and outcomes for people in Scotland.
Date submitted: 07 October 2022
Submission: PDF
Scottish Parliament: Witchcraft Convictions (Pardons) (Scotland) Bill
Remit: A proposed Member’s Bill seeking views on revisiting past injustices and pardon all those convicted under the Witchcraft Act 1563.
Date submitted: 15 September 2022
Submission: PDF
Scottish Government: Strategic Review of Funding and Commissioning of Violence Against Women and Girls Services: Call for Views
Remit: To inform the development of a new funding model that will ensure high quality, accessible specialist services across Scotland for those experiencing any form of violence against women and girls.
Date submitted: 15 August 2022
Submission: PDF
Additional information:
– 01 August 2022 Letter to review group requesting consultation withdrawn and reissued due to the unlawful redefinition of “woman”.
– 06 August 2022 Letter in response to the minutes of review group meeting.
– 12 August 2022 Email to Scottish Ministers
Scottish Parliament, Constitution, Europe, External Affairs and Culture Committee: Inquiry into Scotland’s Census
Remit: To examine the outcome of the Census, focusing on the quality of the data collected, identifying any gaps and how they could be filled.
Date submitted: 12 August 2022
Submission: PDF
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
Additional information:
– 27 May 2022 Joint letter to the committee re Scottish Government’s handling of the Bill development.
– 31 May 2022 Susan Smith, FWS giving evidence to the Equalities, Human Rights and Civil Justice Committee (Official Report and Video).
– 30 August 2022 Supplementary evidence re the impact of our second judicial review on Gender Representation on Public Boards (Scotland) Act.
– 30 August 2022: Supplementary evidence re the Cabinet Secretary’s comments on single-sex exceptions in the Equality Act.
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)