Responding to female genital mutilation: multi-agency guidance
A framework for agencies and practitioners to develop and agree processes that promote the safety and wellbeing of women and girls.
3. Policy: all agencies
Agencies such as the NHS, Police Scotland, education and social work services have a statutory responsibility to protect girls and young women at risk of FGM. They must ensure that policies and procedures are clear; staff are supported and equipped to undertake the duties expected of them; and that there are clear lines of accountability.
Although much of this guidance is about identifying risk and responding to harm, the best way to protect girls and women is to prevent and end FGM.
Evidence shows that efforts to prevent and reduce FGM are most successful when the communities affected are actively and directly involved, and supported to be so, as partners. This means that agencies need to work with communities; listen to their concerns; and find solutions and services which are relevant and workable.
In 2016, the Scottish Government published a national action plan on FGM  .
Policy and protocol
Agencies should have FGM protocols and pathways for internal communication, responding and referring. They should also develop multi-agency protocols and pathways so that there are consistent approaches and clear expectations across agencies.
Agencies should respond to FGM using existing child and adult protection structures, procedures and policies, including multi-agency arrangements. If FGM is not explicitly included in these, they should add it urgently so that staff know how to respond to a report, suspicion or risk of, or actual FGM.
Policies and procedures should take account of the characteristics of FGM. Risk may escalate or reduce through childhood and adolescence. Partner agencies may need to update one another and review decisions and actions regularly, from a child’s birth onwards
Each organisation should have a designated FGM lead or single point of contact.
In education, there should be an identified operational lead, with whom the ‘designated member’ of staff for child protection can consult. They should monitor information to identify when a child in the school or community may be affected. The lead individual should have, or develop, expertise about FGM. They should be able to advise education establishments about identifying and referring a child at risk and how their agency can contribute to risk reduction and the Child’s Plan.
In social work, there should be an identified operational lead who can be contacted for advice or guidance about FGM. The lead individual should have, or develop, expertise about FGM.
In each health board, there should be a clinical lead who is a senior clinician. If the clinician is from mental health services, they should liaise with other clinical services. Health boards should notify other professionals and the community of the name and contact details of the FGM clinical lead, and a named deputy to cover for absences. The clinical lead should have links to the gender-based violence ( GBV) operational lead, child protection lead, adult protection lead and others as relevant for individual children and young people.
Data recording and monitoring
Agencies should review data recording and monitoring systems to include FGM where possible.
All agencies should gather, record and collate data about FGM. This is important for understanding the needs of individuals and communities, for commissioning services and for raising awareness. It also helps with identifying risk, intervening promptly, and noticing what is happening within communities.
Health boards should gather anonymised data in order to assess local health and social work needs and to contribute to ISD national data gathering from hospitals, community services and GP practices. It is important for hospital staff to record issues related to FGM on the discharge summary and/or letter to the GP practice, even if FGM is not the reason for attendance. FGM cannot be coded if it is lost in the clinical records. GP practices should use the appropriate ‘Read code’ for FGM.
Agencies should introduce or strengthen information sharing on FGM so that they can protect women and girls. They should ensure that staff are aware of national guidance and local child protection procedures, and that this includes procedures for sharing information  .
Agencies should make sure that staff know that they:
- Should record any concerns.
- Must share child protection concerns with other key professionals.
- Share information within the context and boundaries of Data Protection Act ( DPA).
- Should always share information with the Lead Professional consistent with GIRFEC if a child is involved, or with the adult support and protection lead when relevant.
Staff development and support
Each agency is responsible for ensuring its staff are competent and confident in identifying and responding to FGM.
Each agency must ensure that its staff are competent and able to promote, support and safeguard children’s safety and wellbeing. This includes providing training and development; and having communication protocols and clear standards.
Public protection chief officers groups should ensure that multi-agency training is developed to enhance that done by individual agencies.
Different staff groups have different skills, knowledge and responsibilities. Staff from all agencies should be confident about their own roles and how these fit into the wider picture.
All staff should know their agency’s policy on FGM, and where they can get information, training and support.
Given the relatively few cases of FGM in Scotland, agencies should make training on FGM a priority. In order to prevent harm to girls, trained professionals need to work closely with families, over time, to assess risk, and intervene if necessary.
Information, training and other materials
The Scottish Government has commissioned information, training and other materials. These include:
- A DVD for training and awareness raising: Sara’s Story  .
- Information leaflets for practitioners.
- Training pack and risk assessment tool for practitioners.
- Scottish Government statement opposing FGM. This statement is for people to show to family or friends, when travelling abroad, to explain that FGM is against the law in Scotland and the UK. It may help them resist pressure from relatives, friends and communities.
These materials are at: http://onescotland.org/equality-themes/gender/female-genital-mutilation-fgm/
Service capacity and sustainability
Demand on services may increase as more women come forward, and staff become more skilled in identifying FGM. Migration and population movement may also increase demand for services.
Agencies need to plan for this: both succession planning for the workforce and on-going staff training.
Given the potential for harm, FGM should be embedded within child protection services. It is also important to embed FGM services within existing violence against women/gender-based violence services, given the significant overlaps, for example in dealing with trauma, disclosure, safety and the sensitivity of the issue.
Given the health consequences of FGM, the NHS is likely to be in contact with survivors of FGM and their children. There are different points of entry to the health service where this may be identified. The Scottish Government Health and Social Care Directorate has issued guidance  on developing service specifications to meet the needs of survivors.
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