Publication - Consultation paper

Equally Safe draft delivery plan consultation 2017-2021: response analysis

Analysis of consultation responses on the draft delivery plan for Equally Safe: Scotland's strategy for preventing and eradicating violence against women and girls.

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111 page PDF

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Equally Safe draft delivery plan consultation 2017-2021: response analysis
Cross Cutting Actions

111 page PDF

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Cross Cutting Actions

In addition to the four priority areas, the Equally Safe Delivery Plan laid out a set of cross-cutting actions, organised under the 6 headings of "a human rights framework", "all forms", "all women", "all children", "accountability", and "participation".

As with the priorities, respondents were asked if they agreed that these were the correct cross-cutting actions, any that they particularly supported, any they did not support and anything that they thought was missing/should be added to the cross-cutting actions.

Q17. Do you agree or disagree that the actions listed as cross cutting are the right actions to help meet the overall objectives of the delivery plan?

Sixty-one respondents answered Q17. Around two thirds (67%) agreed that these were the correct cross-cutting actions, (12%) disagreed and a fifth (20%) neither agreed nor disagreed (see table 6 below).

Table 6: Q17. Do you agree or disagree that the actions listed as cross cutting are the right actions to help meet the overall objectives of the delivery plan?

% No.
Agree 67% 41
Disagree 11% 7
Neither Agree nor Disagree 20% 12
N = 61

Totals may not sum due to rounding

Support for the cross cutting actions

Q18. Please tell us about any of the cross cutting actions that you are particularly supportive of.

Table A13 in Annex 1 lists the cross cutting actions that respondents said that they were particularly supportive of. Some respondents stated that they were supportive off all the cross cutting actions listed.

Of actions that were singled out by respondents as being ones that they were particularly supportive of, the most popular actions were:

  • Build the gendered analysis into the implementation of Scotland's first Human Trafficking Strategy, ensuring that interventions recognise the particular inequalities women who are trafficked experience (9)
  • Publish a report setting out what we are doing to implement the Istanbul Convention in Scotland (7)
  • Commission a mapping of exit routes, to inform guidance to public and third sector organisations on how to support women experiencing commercial sexual exploitation including prostitution (7)
  • Ask black and minority ethnic representatives to help us to identify specific steps to tackle violence against BME women and girls (7)

A human rights framework

A common response was for respondents to say that they were generally supportive of taking a human rights approach, rather than to single out particular actions relating to human rights that they were particularly supportive of.

"We fully support the explicit recognition of violence against women and girls as a fundamental violation of human rights, and the placing of human rights at the centre of the draft Delivery Plan."

- Academic/research

There was support for the two actions around the Istanbul Conventions, supporting its ratification, and setting out what Scotland is doing to implement it.

"Implementation of the Istanbul Convention in a Scottish context illustrates the SG continuing priority of a zero tolerance approach to VAWG."

- Third Sector

All Forms

There was support for actions under all forms, which covered a range of different types of VAW.

"We welcome the actions to address online hate and misogyny, human trafficking, female genital mutilation and forced marriage. We welcome the actions in relation to mapping exit routes to support women experiencing commercial sexual exploitation including prostitution and engagement with stakeholders on the findings of research into the evidence to the impact of criminalising the purchase of sex."

- Violence Against Women / Gender Based Violence Partnership

"In our recent Scottish LGBTI hate crime survey, online abuse was the fourth most prevalent type of hate crime experienced by LGBTI people, particularly LBT women who reported consistently higher levels of online abuse compared to male respondents. We support the commitment of the Scottish Government to review the prevalence and nature of online abuse, and identify any measures needed to tackle it."

- Third Sector

All Women

There was support for recognising that certain groups of women might be particularly vulnerable due to a range of other protected characteristics.

"The inclusion of minorities within these in order to understand particular obstacles these women face is also welcomed. Cross cutting actions that reference the likes of BME and LGBT women are illustrative of the SG's commitment to eliminate abuse against women of all backgrounds."

- Third Sector

"We are pleased to see that groups who are particularly vulnerable have been identified, such as black and ethnic minorities, lesbian, bisexual and transsexual women and girls, disabled women and refugees."

- Other Public Body, including Executive Agencies, NDPBs, NHS etc.

All Children

Respondents indicated their support for actions contained under the "all children" heading.

"We are supportive of actions to ensure the impact of domestic abuse on children is recognised and that children are effectively supported."

- Third Sector

"In particular, we welcome plans for a refreshed child internet safety action plan as our young members have highlighted this as an area where they would like more education and support."

- Third Sector


Under accountability, there was only one action that respondents specifically stated that they were supportive of, the action to "embed the Sustainable Development Goals – including Goal 5, which calls for gender equality and the true empowerment of women and girls – in Scotland Performs".


There was support for a pilot programme of participation with affected groups of women, children and young people, and to capture learning from this. There was also a feeling that participation needed to be supported in the longer term beyond a pilot.

"[Our] members warmly welcomed the action to improve participation of those with lived experience of gender-based violence and were also keen to see a commitment to ongoing participation work, beyond the pilot period, built in to the Plan."

- Third Sector

Cross cutting actions that aren't supported

Q19. Please tell us about any cross cutting actions that you don't agree with.

Some respondents said that there were no cross cutting actions that they disagreed with/that they agreed with them all.

As can be seen in table A14 in Annex 1, respondents were unlikely to disagree with any of the specific cross cutting actions. The most common criticism of the cross cutting actions was that it was unhelpful and disjointed to have them separate from the priority actions. In particular there was a strong feeling that "all forms" of violence needed to be better integrated into the priorities, and it was felt that by having actions relating to commercial sexual exploitation, female genital mutilation and forced marriage in the cross cutting actions but not specifically mentioned in the priority actions, they was being presented as less important than other forms of violence, such as domestic abuse, which is specifically referred to in the priority actions.

"Overall, we would echo the VAW Network's response that it is unhelpful to have some forms of VAWG (most notably Domestic Abuse) under Equally Safe's key priorities and then others (including CSE, FGM and Forced Marriage) under 'cross-cutting actions' as this creates the impression that these are of lesser priority. [Our organisation] works to raise awareness of the continuum of VAWG and to raise awareness of the connections between all forms of violence. The superficial divide created by the different treatment in this plan is unhelpful in taking this work forward."

– Third Sector

"The layout of this section is somewhat confusing as it's unclear as to why it sits separately from the Equally Safe key priorities. It would be clearer if all actions were outlined in the same section, giving equal gravitas to VAWG issues beyond domestic abuse."

- Violence Against Women / Gender Based Violence Partnership

There was a feeling that some of the actions needed to be strengthened and go further, particularly those relating to commercial sexual exploitation (discussed more under missing cross cutting actions). It was also noted that more clarity and details were required around certain actions and how they would be delivered.

Actions that are missing/should be added to the cross cutting actions

Q20. Are there any cross cutting actions that you think are missing?

Respondents who answered this question, identified a range of actions that they felt were missing, and highlighted where they felt that existing actions should be strengthened and go further, as shown in table A16 in Annex 1.

Key issues respondents raised included; the need for stronger actions relating to tackling commercial sexual exploitation, the need to align Equally Safe with other SG polices and relevant UN conventions, and particular concerns around the potential impact of Brexit on human rights and the need to mitigate against this.

Human Rights Framework

As mentioned elsewhere, it was felt that responsibility for delivering the Human Rights actions was wider than the Scottish Government, and that all public sector agencies have a duty to incorporate a human rights approach into their services, and therefore relevant agencies should be being encouraged to include this in their Equality Outcomes,

Concerns were raised about the potential impact of Brexit on human rights, and the desire to ensure that the certain EU laws and protections, and the European Convention on Human Rights would still be adhered to in a post-Brexit Scotland. Human rights in general, women's rights, the rights of children, and LGBTI rights were felt to be potentially at risk. One organisation spoke of "fear" among women about their rights.

"We believe that the impact of Brexit on human and children's rights must be taken into account, and every effort must be made to ensure that the best bits of EU law become enshrined in Scottish law. The EU has certain built-in protections (for example for victims of trafficking or child abduction) but what will be the future of those here in Scotland after Brexit?"

- Representative Body for Professionals/Trade Union

Another issue that it was felt could get worse in relation to Brexit, was the plight of women with no recourse to public funds due to their immigration status. It was felt that they were particularly vulnerable to being unable to escape from violent situations due to their economic circumstances, and that the delivery plan should address this.

"We believe this should include looking at those women who are affected by 'no recourse to public funds.' Women from the EU as well as non EU women are being denied safe ways to end domestic abuse due to their immigration status. This problem is only going to get worse with Brexit. Many women who cannot access public funds or services either do not leave abusive relationships or end up going back because their situation is so difficult."

- Representative Body for Professionals/Trade Union

It was noted that the delivery plan should be more explicit about the rights of the child and aligning the actions in Equally Safe with the SG's commitment to the United Nation Convention on the Rights of the Child ( UNCRC).

All Forms of Violence

There was a strong feeling that the actions relating to commercial sexual exploitation ( CSE) needed to be strengthened.

Specific suggestions included:

  • Criminalise the purchase of sex/ Adopt the "Nordic model"(going further than the current action to engage with stakeholder on research around this)
  • Decriminalise the women who are engaged in prostitution
  • Provide and fund specialist services to help women exiting prostitution, provide support and advocacy, and ensure women have alternatives to prostitution
  • Improve the ability of mainstream services to identify those who are involved in CSE and signpost them to appropriate services
  • Address the vulnerability and needs of people who may have been sexually exploited as young people and then end up in prostitution as adults
  • Challenge public attitudes which condone commercial sexual exploitation and views it as less harmful than other forms of VAW
  • Work with COSLA and local authorities to close down lap dancing venues

"The actions in relation to CSE, particularly prostitution are weak. They do not reflect the stance in Equally Safe which considers prostitution to be a form of VAW which contributes to women's inequality and that a 'challenging demand' approach is supported by international research evidence"

- Academic/research

"The broader response to CSE should be strengthened. For example, there should be actions to decriminalise women engaged in prostitution and other forms of CSE, and there should be clear actions (that go beyond 'mapping') about developing and focusing on a routes out of CSE approach. Equally, there should be clear actions to reflect a 'tackling demand to CSE' approach through criminalising perpetrators."

- Violence Against Women / Gender Based Violence Partnership

"Women exploited in prostitution are no longer criminalised for the selling of sex and prostitution is recognised as survival behaviour."

- Violence Against Women / Gender Based Violence Partnership

"Challenging attitudes which condone and perpetuate CSE and raising public and professional awareness of the links between different forms of VAWG, the harm caused by CSE and the need to tackle demand."

- Violence Against Women / Gender Based Violence Partnership

It was also felt that actions were required to tackle harm caused by the internet, including online pornography, as pornography can fuel unhealthy attitudes to women and contribute to other forms of VAW. There was a suggestion that the Scottish Government should press the Westminster Government to extend the definition of "extreme pornography" under part 3 of the Digital Economy Act 2017 so that more pornography can be caught and regulated under that definition. There was another suggestion that the action plan on child internet safety should be extended to vulnerable adults, as they may be particularly at risk of online harm.

It was felt that some agencies and professionals lacked confidence in their technical skills to support women facing online abuse, and that this should be addressed.

As well as access to online pornography, it was noted that the internet is used as a tool to facilitate other forms of VAW, such as advertising women for prostitution, "sex for rent" adverts (where accommodation is offered to a woman on the basis of her providing sex), facilitating trafficking of women, and inappropriate sexting.

It was also noted that technology could be helpful in keeping women safe, for example by allowing them to record instances of abuse, and it was felt that professionals should do more to support women who use technology in this way.

"Our 2017 joint report with CYCJ, Over the internet, under the radar, suggested a lack of confidence among professionals in dealing with online behaviour, and a lack of consistency in responses. We would suggest that throughout the delivery plan there may need to be greater consideration of whether actions effectively address online forms of and context for gender based violence."

- Third Sector

"Our research found that almost 1 in 5 women surveyed had used technology to capture evidence about their abuse, and when asked "How do you think technology can be improved to help survivors?" the second most popular answer (13.3%) was to be able to safely record abuse. We believe statutory services have a role to play in building victims' confidence in using technology to help build evidence as well as to contact the Police and other support services"

- Third Sector

It was felt that stalking should be included. In particular a national campaign to raise awareness, and encourage women to report it to the police was suggested.

It was also mentioned that whilst there was an action looking at online hate and misogyny, it would perhaps be more useful to have an action that looked at misogyny and gender based hate "across all spheres of contact (online, face to face, schools etc.)."

It was suggested that the action around FGM "develop multi-agency national guidelines for tackling female genital mutilation" should go further and be about implementation and monitoring of the guidelines. There was also a suggestion that education and awareness raising were required around FGM, rather than focussing solely on the perpetrators of FGM.

It was suggested that the three actions around forced marriage be grouped together as one objective and then be sub-divided into specific actions for identified agencies, currently they all sit with the SG.

All Women

It was felt that more needed to be said around "all women", and in particular, making specific reference to a wider range of women across all protected characteristics, rather than only referring to LBT women, disabled women and BME women. Specific mention was made of Muslim women, in relation to Islamophobic violence they might face. In addition to the protected characteristics, other women may also be additionally vulnerable, such as those living in poverty, those with insecure immigration status, those living in remote and rural communities, those involved with the criminal justice system, and a recognition that women's needs will vary across the course of their life. More needed to be done to address additional barriers which women with protected characteristics and/or additional vulnerabilities might face.

"ALL women section – there are already legal duties around the protected characteristics – all should be considered here."

- Violence Against Women / Gender Based Violence Partnership

"We would like to see the list expanded to include other vulnerabilities, such as those with learning disabilities, older women, pregnant women etc."

- Other Public Body, including Executive Agencies, NDPBs, NHS etc.

"While sometimes referred to as 'hidden victims' [our organisation] believes we're just not looking in the right place, and could share learning with Scottish Government about how to remove barriers which prevent certain age groups or communities from accessing support."

- Third Sector

It was felt that the actions around all women could be strengthened ( e.g. around engaging with BME women), and also be broadened out, for example to do more to include those with learning disabilities. There was also a feeling that when engaging with stakeholders, it was important to involve the right organisations, and that these might not always be the most obvious. E.g. it was suggested that certain service providers would be aware of the difficulties they faced in making their services accessible and that this information needed to be included, as well as information for disabled people's organisations.

"Disabled people exist throughout society and interact across all levels of organisations. Partners therefore believe that the consultative action listed under 'All women' should be wider than consulting with disabled people. For example, service providers (Women's Aid, Homeless etc.) readily know of the difficulties faced by disabled people trying to access refuge accommodation due to a lack of disabled facilities, while disabled groups are often unaware of this information."

- Violence Against Women / Gender Based Violence Partnership

All Children

One children's charity was concerned that children were not well enough integrated throughout the delivery plan as a whole, and felt that for some actions it was unclear whether they related to children as well as women.

"A key concern with how the delivery plan is structured as a whole is that the various forms of gender based violence and considerations relating to children are not integrated throughout. Even within the cross cutting actions there is a lack of integration, for example the UN Convention on the Rights of the Child does not appear in the human rights framework, despite being identified in the Equally Safe Strategy. We have commented in other answers that we are not always clear whether actions in individual priority areas apply across all forms of gender based violence and include consideration of children."

- Third Sector

It was felt that childhood sexual abuse needed to be mentioned within the delivery plan, and that a holistic approach to childhood sexual abuse was needed. In addition it was mentioned that there is a need for support and services for adult survivors of childhood sexual abuse.

"We note that there is no mention of Child Sexual Abuse in the delivery plan, though this is a form of gender based violence identified in the Equally Safe Strategy. We note that there is one single mention of Child Sexual Exploitation in the delivery plan, and this is a cross-reference to the existence of a national action plan. It is crucial that Child Sexual Abuse and Child Sexual Exploitation are integrated into the delivery plan for the Equally Safe Strategy to achieve its objectives. We would like to see greater clarity throughout the delivery plan about how children and the full range of forms of gender based violence are integrated into the priority areas."

- Third Sector

In relation to the action to "continue to implement the National Action Plan to Prevent and Tackle Child Sexual Exploitation, published in March 2016" it was mentioned that the Care Inspectorate have collected information from Community Planning Partnerships on how they are responding to prevent and reduce risks to children and young people from child sexual exploitation. It was therefore suggested that the action include a commitment to taking this learning forward to support continuous improvement.

There were calls for legislative change that would address the issue of "justifiable assault", where a parent slaps a child as punishment, and provide children and young people with "equal protection from assault".

"Equal protection from assault is a right that all children and young people are entitled to, and is particularly relevant to Equally Safe with regards to evidence that indicates a link between physical punishment and adult aggression within intimate partner relationships… Evidence clearly links experience of abuse in childhood to perpetration in adulthood."

- Third Sector

There was a feeling that the action to "ensure that children's interests are better reflected in the justice system and that their voice is heard" should go further and include the civil courts, and in particular child contact hearings.

There was a feeling that the action to "ensure the Domestic Abuse Bill effectively acknowledges the impact that domestic abuse can have on children through the operation of a statutory aggravation to the new offence of domestic abuse" also needed to go further, and acknowledge that a child does not need to directly witness domestic abuse in order to be affected by it, and that the psychological abuse of and coercive control of a child also needed to be taken into account.

It was mentioned that looked after children should be explicitly mentioned as a particularly vulnerable group, and that the delivery plan should say something about the "responsibilities of corporate parents to safeguard their rights and promote their wellbeing". - Academic/research. It was highlighted that women and children continue to be at risk of abuse after they have left an abusive environment, and that agencies need to be aware of the risk of post-separation violence, e.g. when managing contact arrangements.


A number of accountability mechanisms which exist within the public sector were mentioned, including NHS Board Annual Reviews, and the scrutiny of Single Outcome Agreements and Health and Social Care Partnerships' strategic priorities by the SG. It was suggested that these mechanisms could be included in the delivery plan. It was noted by one responded from within the NHS that as far as they were aware there had never been a question relating to Gender Based Violence within their NHS Board Annual Review.

"Without that level of scrutiny, issues within the NHS risk becoming "non-issues" and do not warrant much priority within the organisation. Without that legitimacy, then simple activities like access to training opportunities for staff, support from IT colleagues, endorsement of GBV-related policies by the organisation (including staff side organisations) all become a challenge."

- Other Public Body, including Executive Agencies, NDPBs, NHS etc.


There were fairly few comments around participation. The need for longer term participation (beyond the pilot period) and broadening out participation across VAW partners were mentioned.. It was seen as important that the voices of women and children with lived experience of gender based violence and domestic abuse are used to inform and influence the Equally Safe strategy. It was noted that all public sector agencies have a duty to ensure that communities have an opportunity to contribute to and shape services and it was suggested that existing structures which exist through community planning partnerships and health and social care partnerships could be used for community engagement around gender based violence. However, it was felt that in order for that to happen, the requirement would need to specified within the delivery plan. The Community Empowerment Act was also seen as a potential vehicle for participation activity.

Other suggestions

Amongst the other suggestions provided for cross cutting actions that were missing, the need for a gendered approach to VAW/ gendered analysis of abuse was the most frequently mention.

"An additional action should include how to support the national agendas for adult survivors of child sexual abuse and child sexual exploitation to understand and reflect the gender analysis. Both approaches are currently gender neutral and this fails to recognise the differences in experiences of women/men girls/boys and the context in which abuse is experienced and perpetrated and can potentially undermine the work of Equally Safe or put the work streams at odds with each other."

- Violence Against Women / Gender Based Violence Partnership

The need for effective training of professionals, possibly using a human rights based framework, in order to support the delivery of Equally Safe was also mentioned.