Eradicating female genital mutilation - national action plan 2016-2020: equality impact assessment

Equality Impact Assessment (EQIA) record for Scotland's national action plan to prevent and eradicate Female Genital Mutilation (FGM) 2016 to 2020.

Stage 4: Decision making and monitoring

Identifying and establishing any required mitigating action

Have positive or negative impacts been identified for any of the equality groups?


Is the policy directly or indirectly discriminatory under the Equality Act 2010 [4] ?


If the policy is indirectly discriminatory, how is it justified under the relevant legislation?


If not justified, what mitigating action will be undertaken?


Describing how Equality Impact analysis has shaped the policy making process

We held a series of roundtable events in summer 2015 with key community stakeholders, including DARF, Kenyan Women in Scotland, Community Infosource and others. These were used to listen to both their anxieties about how aspects of this approach would be carried out so as not to cause harm to relationships between community organisations and the communities they are so vital to, and also to ensure the cultural sensitivity surrounding this practice and its deep rooted origins in cultural tradition was fully taken on board in the development of the National Action Plan. We also listened to their ideas around how best to engage and consult with communities and ensure that the aims of this policy are met by them.

Some of the issues raised at these meetings include but are not limited to:

  • Identify the correct questions to ask and when they need to be asked
  • Engagement has to inform processes and be embedded
  • Engaging with communities and what this actually means
  • Language used/ Definitions
  • Cultural awareness
  • Joining up of grassroots work and service provision
  • Community leaders identified and engaged with – Engagement and Communication co-ordination
  • How can we measure progress?

The development of this policy has been informed by the outcomes of this Equality Impact Assessment. As a result of the data and evidence gathered, the Scottish Government is looking to work with community organisations and partners to ensure there is a more robust recording procedure, and that those cases that have been identified are dealt with in a professional and sensitive manner. Healthcare professionals have been asked to record the diagnosis and types of FGM, together with any corrective procedures in the appropriate clinical records, including the hospital discharge summary. The condition is then able to be coded and relevant codes for hospitals and primary care have been provided to encourage national consistency. This should assist in collecting baseline information regarding some of the aspects of FGM, starting with the healthcare services.

Information Services Division ( ISD) has plotted data collection approaches, to deliver more robust monitoring system in place for 2016/17 in Scotland. ISD have also issued guidance on the use of FGM codes to coders in the Scottish Clinical Coding Standards March 2016.

  • Impact of any new legislation

Any issues in relation to any new legislation in Scotland (along the lines of that contained in Part 5 of the Serious Crime Act 2015) were discussed with the Female Genital Mutilation Short Life Working Group ( FGM SLWG) throughout the development of the FGM National Action Plan. Due consideration was also given to the impact on equality as actions within the plan were agreed.

The SLWG comprised of membership from Scottish Government, Police Scotland, Social Work, NHS Scotland, Education Scotland, third sector and community based organisations

This EQIA has helped develop better outcomes for people and communities by working with community organisations and engaging with communities to ensure they are empowered to become part of the solution, and by ensuring they have been heavily involved in forming the Actions that are the basis of this policy. The feedback received from the various roundtable events coupled with comments received on the draft National Action Plan helped to shape the Actions required to address the complex needs of FGM survivors. The draft National Action Plan also went to consultation with community organisations, grass roots activists and those affected by FGM. All of this contributed directly to the final draft of the National Action Plan.

There have been no cost or resource implications as a result of this EQIA analysis.

Monitoring and Review

As part of the implementation and development of this policy, an implementation group will be set up to monitor and evaluate the specific actions identified in the National Action Plan. There will be a number of sectoral based implementation plans to take forward the actions and activities for particular areas and organisations. These will then nominate representatives to report to the larger National Implementation Group on progress. As part of the implementation process, we will build in an Equality Impact Assessment review to ensure that all and any impacts of this policy are not having any adverse effects and that opportunities to advance equality and foster good relations are considered.


Email: Bruce Sutherland,

Phone: 0300 244 4000 – Central Enquiry Unit

The Scottish Government
St Andrew's House
Regent Road

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