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Publication - Progress report

National action plan to prevent and eradicate FGM: year three report

Published
8 November 2019
Topic
Health and social care
ISBN
9781839603273

Update on the progress that has been made since the publication of the national action plan to prevent and eradicate Female Genital Mutilation (FGM) in February 2016.

View supporting documents Supporting documents

Annex A

Overarching objectives

Objectives Actions Activities Action Owners Summary of Progress
Positive gender roles are promoted to ensure that women and girls affected by FGM are empowered to achieve their full potential FGM is identified within overarching prevention work on Violence Against Women and Girls Review Violence Against Women and Girls Strategies and Action Plans to explicitly include actions to prevent the practice of FGM and provide services to those affected by FGM Individual and multi-agency response by CPPs (Community Planning Partnerships), Integrated Joint Boards (IJBs), Police Scotland, Violence Against Women and Girls Partnerships, Child Protection Committee (CPC) Scotland, Multi-Agency Risk Assessment Committees (MARACs) and Multi-Agency Partnerships 1. Honour Based Violence, including FGM is explicitly referenced in the Equally Safe Strategy.

2. The multi-agency Violence Against Women Partnership Guidance notes that every local authority area in Scotland is expected to have a multi-agency partnership in place that has strategic responsibility for working to address all forms of violence against women and girls, including FGM.
3. NHS Boards have incorporated FGM into their local action plans on gender-based violence.
Gender based violence, including FGM, is recognised as a public health issue Public health strategies and services involve partner agencies and community organisations to raise awareness of the right of all women and children to be free of FGM All Statutory and Third Sector Organisations 4. FGM, as part of the overall narrative on gender-based violence, is included in the multi-agency Violence Prevention Framework developed by the Scottish Public Health Network, which reports to Scottish Directors of Public Health Group.
Women and men have equality of opportunity, particularly with regard to access to resources Public sector agencies understand and fulfil their general and specific duties as set out in the Equality Act 2010, and include FGM within gender-based violence strategies Review gender-based violence strategies and action plans to explicitly include access to resources to enable public sector organisations to understand their duties to prevent FGM and provide services to those affected by FGM All statutory organisations 5. A multi-agency writing group, with membership from the statutory and third sectors, and community based organisations developed multi-agency guidance for organisations responding to, and supporting those affected by FGM.

6. The National Child Protection Guidance provides a national framework within which agencies and practitioners at a local level can understand and agree processes for working together to support, promote and safeguard the wellbeing of all children; the guidance includes a section on FGM.
7. The new Female Genital Mutilation (Protection and Guidance) (Scotland) Bill introduced a provision for Ministers to issue statutory guidance on FGM. Subject to Parliament passing the Bill, a full consultation will be conducted to inform the contents of this guidance.
8. To ensure that health professionals in Scotland are able to respond effectively to FGM, the Chief Medical Officer and Chief Nursing Officer have issued three letters since 2014 giving NHS staff advice on FGM, the services most likely to come across it, and the process for recording cases of FGM.
9. Education Scotland have developed a National Improvement Hub, which provides information and support to practitioners. The Hub has a specific page on FGM.
10. Police Scotland have developed Standard Operating Procedures on Honour Based Violence, Forced Marriage and FGM to ensure that their response to FGM is consistent, sensitive and meets the needs of individuals and communities affected.

Prevention Objectives

Objectives Actions Activities Action Owners Summary of Progress
Women and girls potentially affected by FGM feel safe, respected and equal in our communities Provide clarity of legislation and policy position on FGM in Scotland Provide FGM Statement to raise awareness around holiday times to prevent FGM and to be included in Police Scotland initiatives at airports and ports Scottish Government, statutory and
non-statutory organisations including Education, Scottish Airports and Ports, Police Scotland		 11. The Scottish Government has printed a statement opposing FGM to be used by a person at risk who can show it to relatives and/or family friends when abroad to remind them that FGM is a serious offence, with serious penalties, in Scotland.

12. UK Border Force, in collaboration with Police Scotland, carried out Operation Limelight in Scottish Airports in Summer 2019. This project sought to
raise awareness of FGM and detect any potential cases of FGM.
13. Police Scotland’s Child Protection Policy team held awareness raising events through December 2018 and January 2019 for Border Force staff and Police Scotland Border Policing Command at both Edinburgh and Glasgow Airports.
Implement an FGM prevention plan to prevent harm, and support women and girls at risk All partners to engage with multi-agency working groups and committees, nationally and at a local authority level Individual and multi-agency responses by
CPPs (Community Planning Partnerships), Integrated Joint Boards (IJBs), Police Scotland, Violence Against Women Partnerships,
Child Protection Committee Scotland, Multi-Agency Risk Assessment Committees (MARACs) and Multi-Agency Partnerships (MAPs)		 14. The Scottish Government Established the FGM National Action Plan Implementation Group, which oversees the implementation of the Action Plan. The group is made up of members from the statutory and third sectors, and community based organisations.

15. Police Scotland operate a Child Protection Strategic Group, which is attended by representatives from the Scottish Government who have responsibility for FGM Policy.
16. See no. 2
Police, with partner agencies, will coordinate local and national media campaigns to raise awareness of emerging forms of abuse Police Scotland 17. See no. 11

18. Police Scotland participate in multi-agency events during 16 Days of Action, and Zero Tolerance Day. Police Scotland currently remain an active participant in the 16 Days of Action Campaign for late 2019
Police Scotland, with partner agencies, will implement prevention strategies to influence social attitudes and reduce vulnerability Police Scotland 19. See no. 10
Police Scotland will review national FGM training to ensure it provides its frontline staff with the skills they need, and enabling multi-agency training. Police Scotland, other statutory agencies, third sector agencies 20. See no. 10
People enjoy healthy, positive relationships and understand the damaging effects that FGM has on those relationships Provide information about FGM and gender equality and children’s rights Raise awareness of FGM and the services available, and development of all communities including young people, men, religious leaders and others, recently arrived migrants, asylum seekers and refugees Scottish Government, third sector and statutory agencies 21. See no. 5 to no. 10
22. Community Info Source are funded through the Equally Safe Fund for their Champions for Change project, which seeks to combat Female Genital Mutilation by working with men in potentially affected communities.

23. Saheliya are funded through the Equally Safe Fund for their Champions for Change project, which trains minority ethnic survivors of gender-based violence to raise awareness in their communities.
24. Waverley Care are funded through the Equally Safe Fund for their My Voice project, which works with communities in Scotland affected by FGM. The project seeks to empower communities to challenge and prevent FGM while supporting the development of culturally sensitive support services for individuals affected.
25. With funding from the Scottish Government, the Women’s Support Project developed a short film entitled ‘Sara’s Story’ which provides information on the causes and possible impacts of Female Genital Mutilation. The film is based on real-life accounts by survivors and is designed to raise awareness, and for use in training and public education.
26. The Women’s Support Project also maintain the FGM Aware Website, which provides information about FGM and resources for training and public education.
Education Scotland will review, update and develop learning resources that can be used in the classroom in an age appropriate manner Education Scotland, NHS Health Scotland 27. See no. 9
Make available, up-to-date factual information on the impact of FGM on the health and wellbeing of the affected individuals NHS Boards, third sector organisations 28. See no. 25 and no. 26
29. Staff at NHS Scotland have access to guidance on the health impact of FGM through their local intranet sites. Some NHS Boards have developed e-learning resources to support this.
Scope the impact and implications that elongation of labia and other practices have on potentially affected communities in Scotland, and develop appropriate responses Scottish Government, third sector organisations, NHS Boards 30. As part of the consultation on the new Female Genital Mutilation (Protection and Guidance) (Scotland) Bill, a public consultation was conducted, which ran from 4 October 2018 to 18 January 2019. This consultation, among other things, sought stakeholder views on whether they thought additional protections needed to be introduced in Scotland in respect of the practice of vaginal/labia elongation. It also asked if stakeholders had any evidence to suggest that individuals in Scotland have been subjected to this practice. The consultation analysis showed that most respondents did not know, or did not support the introduction of additional protections in relation to vaginal elongation. While there was some support for protections here, this was largely based on the principle that this is a harmful practice, rather than the perception that this was a widespread practice that necessitated a specific legislative response. Furthermore, given that vaginal/labia elongation is captured under the World Health Organisation’s definition of type 4 FGM, it is agreed that cases could be addressed under existing and upcoming FGM legislation. Nevertheless, we are committed to continuous engagement with stakeholders on this issue to ensure we remain well informed on the issue.
Individuals and communities recognise the implications and are able to challenge FGM Communities potentially affected by FGM are supported to identify and analyse common issues within affected communities, and develop strategies to challenge behaviour and influence change in communities, service provision, and policy making Investment made in community engagement and development to enable the recognition of the implications of FGM and are able and empowered to challenge the practice of FGM. This is to include all sections of the potentially affected communities, including men, women and children. Scottish Government and other funders 31. See no. 22 to no. 26
Agencies and organisations should publish and maintain online information and resources, e.g. onescotland.org and Scottish Government webpages and FGM Aware, NSPCC Helpline, Scottish Women’s Aid, the Scottish Domestic Abuse Helpline, the free app called Petals Scottish Government and all partners in the statutory and third sectors 32. Scottish Government - OneScotland.org – Female Genital Mutilation page
33. Women’s Support Project - FGMaware.org

34. Education Scotland - National Improvement Hub, FGM Page
35. National Society for the Prevention of Cruelty to Children – FGM information page
Individuals who support FGM change their attitudes and behaviours and are supported to do so Statutory Services work with partner agencies and community organisations to raise awareness of the right of all women and children to be free from FGM Investment to be made in community-based engagement and development with all members of the potentially affected communities, including men, women, children and young people to change attitudes and behaviour Scottish Government and other funders 36. See no. 22 and no. 23
37. In 2018/19 Health Scotland funded and supported a series of community engagement sessions led and co-ordinated by KWISA across six NHS Board areas in Scotland. These events brought together local women and health staff to consider the issues important to women in the communities and to encourage building of relationships and sharing of information between them. There will be a full report from the sessions and recommendations for future action.

Protection Objectives

Objectives Actions Activities Action Owners Summary of Progress
Justice and child protection responses to FGM are robust, swift, consistent and coordinated Police to ensure that they respond sensitively to concerns raised by professionals and others To develop awareness of, and access to the guidance for police on how to respond to FGM Police Scotland 38. See no. 10
Statutory agencies respond appropriately to children at risk of FGM Children affected by FGM have a child’s plan CPP, IJBs and Social Work Scotland, Child Protection Committee Scotland 39. (Note: No specific reference to a ‘child’s plan’ but below is a summary of how Social Work would respond to a case of FGM. This may differ from region to region, but this is the general standard approach as provided by Social Work Scotland)
a. FGM is a form of child abuse and a cause of significant harm. Child protection procedures apply.
b. All inter-agency approaches should be carried out, as far as possible, in partnership with parents/carers unless they themselves are the source of the risk. The formal mechanism for information sharing and resolving next steps is an Inter-Agency Referral Discussion (IRD); this must involve Police, Health and Social Work in consultation with Education and any other relevant professionals as/if appropriate.
c. Where risk is identified, but not immediate, some areas report that they would routinely convene a child protection case discussion, share information, assess risk, and agree actions required. If ongoing risk of significant harm is identified, child protection processes apply.
d. Consideration can be given at any and all stages to the need for referral to the Children’s Reporter. If a hearing is called, one of the options would
be a compulsory supervision order, which could restrict travel.
Female Genital Mutilation should always be seen as a cause of significant harm, and also seen in the context of GIRFEC or local inter-agency child or adult protection procedures Local procedures, guidelines and communication strategies should be in place to ensure a coordinated response from all agencies and highlight the issue for all staff that may come into contact with women and children who may be at risk from or affected by FGM in partnership with parents/ carers where appropriate CPP, IJBs and Social Work Scotland, Child Protection Committee Scotland and Adult Support and Protection (ASPC) conveners 40. See no. 39
Those who seek to, or carry out FGM are identified early and held to account by the criminal justice system Ensure legislation to address FGM in Scotland is fit for purpose Scottish Government to continue to engage with potentially affected communities and other relevant stakeholders to consider the impact of any further legislation Scottish Government, Crown Office and Procurator Fiscal Service (COPFS), statutory organisations, third sector organisations 41. The Scottish Government introduced to Parliament the Female Genital Mutilation (Protection and Guidance) (Scotland) Bill on 29 May 2019, which introduces new provisions to strengthen the existing legislative framework for the protection of women and girls from FGM. As part of the development of this Bill, we ran a public consultation from the 4th of October 2018 to the 18th of January 2019, which sought views on the proposed provisions. Furthermore, we hosted a National Summit for Preventing and Eradicating FGM on 11 July 2019, which brought together stakeholders to discuss the new legislation, as well as FGM policy more widely.
Scottish Government to liaise with UK Government to ensure efficacy of existing legislation Scottish Government, COPFS 42. Officials are regularly engaging with the UK Home Office to discuss policies and legislation related to FGM. We are also involved in internal cross-government stakeholder groups.
Assess the numbers being prosecuted for performing, aiding and abetting FGM following investigations by Police Scotland COPFS, Police Scotland 43. There have been no FGM related prosecutions in Scotland.
Consider the existing legislation in relation to elongation and other practices, and cosmetic genital piercings Scottish Government, Police Scotland, COPFS, and other relevant statutory agencies 44. Stakeholder views on whether additional legislative provisions needed to be made with regard to the practice of vaginal elongation were sought as part of the consultation on the new FGM Bill. The analysis showed that stakeholders did not have any evidence to suggest that this practice is widespread in Scotland, and the consensus was that further legislation would not be required. It was also agreed that vaginal elongation could be prosecuted under existing and future FGM legislation, and also under child protection legislation.

45. The consultation also sought views on cosmetic genital piercings so we could develop our policy in this area. Genital piercings are not prohibited in Scotland, we expect the highest professional standards from all those performing cosmetic procedures.
Develop policy, procedure and learning from investigations to ensure consistent police standards are applied across Scotland Establish an effective mechanism to review investigations and ensure adherence to national standards for prevention FGM and management of FGM Survivors Police Scotland 46. See no. 10
47. Local mechanisms are in place, or are being developed for the multi-agency review of IRDs. Internally, Police Scotland holds a Child Protection Detective Inspectors’ Forum, where learning would be highlighted and discussed.
Establish a nationally accessible platform for Police Scotland to identify good practice and learning outcomes from previous investigations Police Scotland 48. Police Scotland has Organisational Learning and Development processes in place across public protection. This is also a consideration for Detective Inspector Forums and the Child Protection Strategic Group.
Develop and implement a communication and engagement plan in order to facilitate partner engagement and support for the delivery of national Child Protection processes Statutory and third sector organisations 49. See no. 14
50. The new Female Genital Mutilation (Protection and Guidance) (Scotland) Bill introduces a provision for Ministers to issue Statutory Guidance on FGM; anyone exercising public functions in Scotland will be obliged to have regard to this guidance. Subject to Parliament passing the Bill, a full consultation will be conducted to inform the contents of the guidance. This Bill also is supported by a comms plan, which seeks to raise awareness of the new legislation, and of existing provisions to protect and support women who are victims of FGM.
Through thorough investigations and development of FGM intelligence strategy, identify and detect perpetrators Work with statutory and third sector partners to agree thresholds for exchanging personal information, initiating investigations, ownership, and deployment of Police Scotland Public Protection Unit resources Police Scotland 51. Information sharing protocols are embedded within local multi-agency Child Protection Procedures, including through IRD processes and reviews.
Monitor impact of gender based hate crime, taking care not to stigmatise individual communities Police Scotland 52. On 14 November 2018, the Scottish Government launched its 14 week consultation: One Scotland: Hate Has No Home Here, which sought views on the proposals for a new hate crime bill following recommendations made by Lord Bracadale’s independent review into hate crime. On June 27, we published the consultation analysis report and the responses will be considered as we develop our consolidated hate crime legislation to be introduced during the current parliament session and ensure it is fit for 21st century Scotland.

Provision Objectives

Objectives Actions Activities Action Owners Summary of Progress
Women and girls who have been affected by, and who are potentially affected by, FGM have access to relevant, effective and integrated services Delivery of coordinated and consistent services via a multi-agency response to those affected, or who may be affected, by FGM Regular multi-agency meetings to exchange information and good practice about FGM locally and with other regions in Scotland Multi-agency response by CPPs (Community Planning Partnerships), Integrated Joint Boards (IJBs), Police Scotland and Violence Against Women Partnerships Child Protection Committee Scotland, Multi-Agency Risk Assessment Committees (MARACs) and Multi-Agency Partnerships (MAPs) and other statutory and third sector agencies 53. See no. 2 and no. 14
All statutory agencies have at least one named professional with expertise on FGM in addition to the lead officer, where they are different individuals All statutory agencies 54. Territorial health boards have gender based violence leads to support development of staff capacity concerning FGM. Each board has a clinical lead for FGM and two have specific specialist midwives for FGM.

55. Police Scotland has a national Child Protection Policy Detective Chief Inspector as a single point of contact.
Consistent recording and reporting of FGM data to inform responsive and high quality service development and monitoring of services Demonstrate improved data capture of FGM
  • Recording
  • Reporting
  • Risk Assessment
  • Referrals / Monitoring
  • Information sharing
 All statutory agencies 56. FGM is recorded in maternity records, along with risk assessment processes undertaken following disclosure

57. Some processes are included in local IRD and iVPD processes.

58. Data recording has been identified as a priority going forward. Colleagues in the Equality Unit are currently engaging with colleagues in Health to begin to shape our thinking in this area.
Multi-agency information sharing protocol developed and publicised locally to statutory and non-statutory sectors All statutory agencies 59. These protocols have been developed in a number of health board areas. Furthermore, Child Protection Processes include provisions for information sharing between statutory bodies, including Police, Health, Social Work and Education to ensure that children at risk are protected.
Each NHS Board has a clear protocol and a referral pathway to ensure a coordinated and comprehensive health and social care service, including generalist and specialist services, are available and accessible informed by the local need Provide information to healthcare staff, including those in general practice and community clinics (paediatrics, genito urinary clinics, mental health, etc.) to enable them to access up-to-date information about the range of health and other local and national statutory and voluntary sector services that offer support to survivors of FGM NHS Boards, IJBs 60. See no. 8
Healthcare workers and other professionals should provide relevant information to survivors of FGM about support services and how to access them NHS Boards, CPPs, IJBs, third sector, university and student college welfare 61. NHS staff have access to information on FGM and details of services through their local intranet. Some NHS Boards have also developed e-learning resources to support this. This supports staff to provide information on services available to FGM survivors.
Individuals who experience trauma as a result of FGM should receive access to trauma informed mental health services NHS Boards, IJBs 62. Each NHS Health Boards has a Transforming Psychological Trauma Training Co-ordinator working across services to support delivery of trauma-informed care. FGM, as part of the wider spectrum of gender-based violence, is included within this.
Through partnership working, improve Police Scotland’s response to FGM and increase opportunity for early and effective interventions in respect of victims and perpetrators Police Scotland to work collaboratively with partners to create national processes for the submission of intelligence on FGM Police Scotland 63. Police Scotland work is ongoing on the Partners Intelligence Portal, which is a partners’ intelligence submission portal.
Improve the reporting methods by third party reporting for those affected by FGM Police Scotland, all statutory agencies, third sector organisations 64. Police Scotland continue to engage with communities to raise awareness and encourage reporting.
Nationally collate the number of child concern referrals/Inter-Agency Discussions (IRDs) received by Police Scotland for FGM, and maintain a national FGM register to provide operational coordination and overall assessment of FGM prevalence across Scotland Police Scotland, Child and Adult Protection Committees, CPC, ASPC Scotland, MARACs and MAPs 65. This action has not been progressed to date due to other priorities. Officials will explore this further with Police Scotland.
Service providers competently identify FGM and respond effectively All statutory organisations equip their workforce with the necessary skills, knowledge and understanding to effectively identify and respond to FGM, identify risk and follow local procedures for reporting child and adult protection concerns To develop multi-agency national guidance for front-line staff and their organisations to address FGM in Scotland NHS Health Scotland, Police Scotland, local authorities, CPPS, higher educational institutions and all relevant third sector organisations 66. NHS Scotland published multi-agency guidance in 2018. This contains detailed guidance for health staff in identifying and responding to the needs of FGM survivors.
All statutory agencies will develop a comprehensive suite of guidance documents to ensure all staff are confident and competent at identifying and responding appropriately to FGM All statutory agencies and higher educational institutions 67. See no. 5 to no. 10
68. NHS Staff have access to information on FGM and details of services through their local intranet. Some NHS Boards have also developed e-learning resources to support this.

69. Police Scotland have information on FGM on their intranet.
Healthcare staff in key settings should be equipped to sensitively enquire about patient experience of FGM and to respond effectively to disclosures of FGM. For example, assess risk and take appropriate actions NHS Boards, NHS Health Scotland and IJBs 70. The primary focus for this has been maternity care. Routine enquiry of FGM has been introduced in most health boards and there is a clear pathway of care provided which includes risk assessment and information sharing. Local NHS Boards have provided training for midwives. In NHS Lothian and NHS Greater Glasgow and Clyde there are also specialist services available within maternity care.
To develop and maintain FGM educational materials and resources for teachers to support children, parents/carers and other networks to include annual safeguarding update Education Scotland 71. See no. 9
Each Child Protection Committee and Adult Protection Committee should have an inter-agency learning and development strategy to reflect the training needs of the multi-agency workforce, with specific reference to the role of the Named Person and lead professional in identifying and responding to women and children at risk of, or affected by FGM Individual and multi-agency response by CPPs (Community Planning Partnerships), Integrated Joint Boards (IJBs) and Violence Against Women Partnerships, Child Protection Committee (CPC) forum, and Multi-Agency Partnerships (MAPs), Social Work Scotland, Scottish Child Protection Committee Chair Forum 72. There is no clear picture of the achievements that have been made against this activity. Scottish Government colleagues will seek to address this moving forward.

Contact

Email: Nadia Abu-Hussain@gov.scot

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