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Correspondence regarding Survivors of Human Trafficking in Scotland (SOHTIS) event: FOI release

Information request and response under the Freedom of Information (Scotland) Act 2002.


Information requested

In the week commencing Jan 5 2026, an event was held on the topic of Violence against Women and Girls, involving ministers, officials and third-sector organisations. The meeting is recounted in this blog here:

https://www.sohtis.org/blog/o3z04yufd1e72q0ljk07y34qhbpnkq

The meeting/event was attended by Siobhian Brown MSP, Minister for Victims and Community Safety, and included attendees from policy teams from the Scottish Government, including those focused on VAWG, Commercial Sexual Exploitation, Human Trafficking & Exploitation, and the Equally Safe in Colleges and Universities core group.

Please provide the following:

  • Any agenda or programme for the event
  • A list of invitees, including but not limited to ministers, MSPs, officials, and external invitees
  • Any minutes that were taken
  • Any speaking note or briefing note developed for Minister Brown
  • The text of invites sent to external invitees

Response

I enclose a copy of some of the information you requested.

While our aim is to provide information whenever possible, in this instance the Scottish Government does not have some of the information you have requested. The reasons why we do not have the information are explained below.

In part, this is because your request relates to an external event that was organised by Survivors of Human Trafficking in Scotland (SOHTIS).

1. Any agenda or programme for the event

A copy of the agenda can be found within ANNEX A. Please note that an exemption under section 38(1) (b) of FOISA (third party personal data) applies to some of the information you have requested.

Exemptions under Section 38 (personal information) of FOISA contains four exemptions, all relating to personal information. Information is exempt from disclosure if it is: the personal data of the person requesting the information (section 38(1)(a)); the personal data of a third party – but only if other conditions apply (section 38(1)(b)); personal census information (section 38(1)(c)); or a deceased person's health record (section 38(1)(d)).

The exemptions in sections 38(1)(a) and (b) regulate the relationship between FOISA, the UK General Data Protection Regulation and the Data Protection Act 2018. Processing of personal data must be fair as well as lawful, so fairness needs to be considered separately. Guidance issued by the ICO in relation to the UK GDPR states that fairness means public authorities should only handle personal data in ways that people would reasonably expect and not use it in ways that have unjustified adverse effects on them. Public authorities should therefore take the following into account: Whether the individual expects their role to be subject to public scrutiny. Consideration should be given to the person’s seniority, whether they have a public profile and whether their role requires a significant level of personal judgement and individual responsibility. Whether any distress or damage would be caused to the data subject as a result of the disclosure; Any express refusal by the data subject; Whether the information relates to the data subject’s public or private life. A person’s private life is likely to deserve more protection. Therefore, to protect those individuals from unexpected public scrutiny and potential distress or damage caused by disclosure, it is considered that the exemption, detailed above, is applicable in these circumstances – particularly given this is a sensitive area of policy.

2. A list of invitees, minutes taken at the event, text of invites sent to external invitees

An exemption under section 17(1) of FOISA (information not held) applies to some of the information you have requested. The Scottish Government does not hold the names of all of those who attended the event, any minutes that were taken or the text of invites sent to external invitees.

This is due to the event being organised by SOHTIS. I have provided a list of known invitees within ANNEX B. In addition, there was also representation from the Scottish Government VAWG Equalities team, but an exemption applies under section 38(1)(b) of FOISA (third party personal data).

This is a formal notice under section 17(1) of FOISA that the Scottish Government does not have all of the information you have requested.

3. Any speaking note or briefing developed for Minister Brown

Exemptions under Section 30(b)(i) – free and frank provision of advice and section 38(1)(b) of FOISA (third party personal data) applies to some of the information you have requested. Please find a copy of some of the information from the Minister’s briefing at ANNEX C. I have also included a copy of the PowerPoint presentation used at the event in case of interest, at ANNEX D.

Exemptions under Section 30(b)(i) (free and frank provision of advice) of FOISA apply to some of the information you have requested. This exemption recognises the need for officials to have a private space within which to provide free and frank advice to Ministers and other officials before the Scottish Government reaches a settled public view. This exemption is also subject to the ‘public interest test’. We have found that, on balance, the public interest lies in favour of upholding the exemption. We recognise that there is a public interest in disclosing information as part of open, transparent and accountable government, and to inform public debate. However, there is a greater public interest in allowing a private space within which officials can provide full and frank advice to Ministers and other officials as part of the Government policy process. This private thinking space is essential to enable all options to be properly considered, based on the best available advice, so that good policy decisions can be taken.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

Contact

Please quote the FOI reference
Central Correspondence Unit
Email: contactus@gov.scot
Phone: 0300 244 4000

The Scottish Government
St Andrew's House
Regent Road
Edinburgh
EH1 3DG

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